ECOSYSTEM PROTECTION
Terms, Principles, and EPA Authorities
Brought to you by the Ecosystem Protection Workgroup
Denise Link Paul Mclver
Karen Hamilton Jim Luey
Peter Ismert Deldi Reyes
Tom Johnson Dave Smith
Gene Kersey Larry Svoboda
Technical Assistance
Andrea Stone
John Michnick Paul Mclver
-------
LET US NOT
GO OVER
THE OLD GROUND,
LET US RATHER
PREPARE
FOR WHAT IS
TO COME
Marcus Tullius Cicero, 106-43 B.C.
Roman Statesman
U.S. EPA Region 8
Technical Library 80C-L
999 18th Street, Suite 300
Denver, CO 80202-2466
-------
wmm v
Rf -:-C' '" ¦ :> ^\V-f%;f ;'**%&'^' ^ .. *~-\ : ¦ i
i - ipi $ m i itippgt wmmrn ¦' ip imMgigiI pig fflmm$$m pi *m pi i Ittiti §
g f ' 4 -' - ,-P' ¦¦.,5 .. S ' ; v' 8 , „ 1 "1 W$w V ;>,v" m •'„ , "V% wi S5 - ' ¦¦ '"¦
. __ __ ... i _____ _ __ . : __
"* , , ''/'{¦• / ' ' ; '
l!"l!!"""'""'.'"" ""''""'"¦¦••¦.'¦¦...../......V...//1...V.¦¦•.;:f;;./.:j.Yiri::in--:)• M^¦¦•¦¦^iriiii'iiti-liiri---Ml- i -i -¦ -m- ¦•'i:i--itri:iliiit
m Clarify ecological terms and concepts
i Describe EPA tools and authorities to
implement ecosystem protection
h Suggest thoughts for reorganization and
actions for leadership
-------
, .¦":¦¦ ' ' ¦
, v ' :w m"'$?;.v- ; " ¦ ^ - r 'vft? ~ rvi:," t?J. * v"< - „ * ;
DRIVING FORCES
1 : .. .
>: / ' / > , > /"'¦' / f * ^ t' ' ^ "/ *
ft Pontic tf%a&wLs
¦ Science Advisory Board Report
Beducing Bisk
¦ Edgewater Consensus
d Five-Year Strategic Plan
¦ National Environmental Policy Act
Enabling Legislation
¦ Federal Natural Resources Agency Birection
-------
WE WON'T BE A SOCIETY IF WE DESTROY THE ENVIRONMENT
Margaret Mead
-------
NATIONAL PERFORMANCE REVIEW
Recommendation ENVOI
DEVELOP CROSS-AGENCY ECOSYSTEM PLANNING AND MANAGEMENT
-------
EDGEWATER CONSENSUS
Even if EPA had perfect compliance with all our authorities, the Agency could not assure the reversal of
disturbing environmental trends. We must collaborate with other federal, tribal, state, and local agencies, as
well as private partners, to reverse those trends and achieve our ultimate goal of healthy, sustainable
ecosystems.
-------
EPA AGENCY-WIDE STRATEGIC PLAN
"Promote ecosystem protection and sustainable development guiding principles, policies, and partnerships to
cultivate an encompassing, multi-media approach to environmental protection, and foster more risk reduction
using the authorities and resources of the statutory programs" (emphasis added).
-------
NATIONAL ENVIRONMENTAL POLICY ACT
PURPOSE
Sec. 2. "The purposes of this Act are: To declare a national policy which will encourage productive and
enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage
to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the
ecological systems and natural resources important to the Nation..."
TITLE I
DECLARATION OF NATIONAL ENVIRONMENTAL POLICY
Sec. 101. (a) The Congress, recognizing the profound impact of man's activity on the interrelationships of all
components of the natural environment, particularly the profound influences of population growth, high-density
urbanization, industrial expansion, resource exploitation, and the new and expanding technological advances and
recognizing further the critical importance of restoring and maintaining environmental quality to the overall welfare and
development of man, declares that it is the continuing policy of the Federal Government, in cooperation State and local
governments, and other concerned public and private organizations, to use all practicable means and measures, including
financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain
conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other
requirements of present and future generation of Americans.
-------
U.S. fish and Wildlife Service
An ecosystem approach to conservation will enable the Nation to more efficiently and effectively conserve
our biological diversity. It is becoming widely recognized that environmental sustainability will only be reached
by taking a holistic approach to resource conservation.
U.S. Bureau of Land Management
The BLM has adopted the principles of ecosystem management to guide its management of the public's lands
and resources... The BLM will make management decisions with a better informed understanding of the
relationship among land management activities, site capability, social and economic demands, and ecological health
and sustainability.
U.S. Forest Service
Ecosystem management points us toward a new vision for the national forests and grasslands. That
embraces the idea that, working with partners and concerned citizens, we can sustain systems that are not only
healthy, diverse, and beautiful but economically productive and useful as well.
U.S. National Park Service
Ecosystem management [is] an approach that can assist the NPS address new issues and problems in order
to improve its stewardship. An ecosystem approach to management will require actions to be targeted to root
causes of problems whether they exist inside or outside park boundaries and encourages a flexible framework for
NPS managers to confront new and profound problems.
-------
U.S. GENERAL ACCOUNTING OFFICE
"The Congress has enacted laws to protect individual natural resources - for example to protect and restore
plant and animal species whose survival is threatened or endangered; to protect and restore air quality; or to
restore and maintain the chemical, physical, and biological integrity of the nation's waters ~ that define
minimum levels of protection to be met or assign responsibility for defining these levels to exective branch
officials... As a starting point, ecosystem management will need to maintain or restore the minimum level of
ecosystem integrity and^functioning necessary to meet existing legal requirements" (emphasis added).
from Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach, U.S.
GAO, August, 1994
-------
Reducing Risk:
Setting Priorities And
Strategies For
Environmental Protection
-------
NOTICE
This report has been written as a put of the activities of the
Sdence Advisory Baud, a public advisory groupjroviding
exUauiuial scientific tnfatmation and adwee to me
A^»t»in«un and other officials of the EwlwiiiiHial
.ftptwllan Agency. The Boari hn^mied to prortete^a
A|u A aagyaa luwu ||m JMaAMte ALja
pfoomns iwii| w wiu nw uwiiiiki o» nus tcpofc
do not MQMiiijr represent the views and pnlUiss of the
Eiivirwuiwiml Protection A^cucy or of other Federal
This particular project was conducted at the reqoast of the
EPA Administrate nd addresses a broader wage of lames
and mucems than most SAB reports. Consequently, many of
the findings and recommendations in this report-have more
of a policy orientation than is usttaDy the i
Cover Photo by Steve Delaney
-------
Reducing Risk:
Setting Priorities
And Strategies For
Environmental
Protection
The Report of The Science Advisory Board-
Relative Risk Reduction Strategies Committee
to
William K. Reilly
Administrator
United States Environmental Protection Agency
September 1990
-------
Science Advisory Board
U.S. Environmental Protection Agency
Washington, DC 20460
September 25, 1990
Mr. William K. Reilly
Administrator
U.S. Environmental Protection Agency
Washington, DC 20640
Dear Mr. Reiily:
Over a year and a half ago, you asked the Science Advisory Board to review EPA's
1987 report. Unfinished Business: A Comparative Assessment of Environmental Prob-
lems, and then assess and compare different environmental risks in light of the most
recent scientific data. You also asked us to examine strategies for reducing major risks
and to recommend improved methodologies for assessing and comparing risks and
risk reduction options in the future. This report and its three appendices have been
prepared in response to your request.
To undertake this project, the Science Advisory Board created a special Relative
Risk Reduction Strategies Committee composed of 39 distinguished scientists and
other experts from academia, state government, industry, and public interest groups.
The Committee carefully considered the reports written by each of its three Sub-
committees-rand the findings and recommendations contained in Reducing Risk flow
from the work of the Subcommittees and reflect study, discussion, and synthesis by the
Committee as a whole. This report has been reviewed by the SAB Executive Com-
mittee and has been formally approved as an SAB document
As you are aware, the Science Advisory Board normally reviews scientific reportsfnr
the Agency and evaluates them on the basis of scientific and engineering
However, in this case our review of Unfinished Business and our analysis o.
reduction options have led us to make findings and recommendations that are more
policy-oriented than is usually the case. We have done this at your request.
This report, together with its three appendices, suggests steps that the Environmental
Protection Agency should take to improve its own efforts — and to involve Congress
and the rest of the country in a collective effort — to reduce environmental risk. We
strongly believe that the Agency should take steps to ensure that this nation uses all the
tools at its disposal in an integrated, targeted approach to protecting human health,
welfare, and the ecosystem.
This report is only a step along a long road. We encourage you to lead the Agency in
taking the necessary further steps as soon as possible.
Sincerely,
Raymond Loehr
Chair, Science Advisory Jonathan Lash
Board, and Co-Chair, Relative Co-Chair, Relative Risk
Risk Reduction Strategies Reduction Strategies Committee
Committee
ii
-------
Contents
Members of the Relative Risk Reduction
Strategies Committee iv
Chapter One: Executive Summary 1
The Concept of Risk 1
The Traditional Role of the Environmental
Protection Agency 3
Unfinished Business 4
The Relative Risk Reduction Strategies Committee.. 5
The Ten Recommendations 6
Chapter Two: Findings 7
1. The Importance of Unfinished Business 7
2. Problems in Ranking ~Risks 8
3. The Extraordinary Value -of Natural Ecosystems.. 9
4. Time, Space, and Risk 10
5. The Links Between Risk and Choice 11
6. Public Perceptions of Risk. 12
7. Relatively High-Risk Environmental Problems ... 13
8. Strategy Options for Reducing
Environmental Risk 15
Chapter Three: The Ten Recommendations 16
Recommendation 1 16
Recommendation 2 —... 17
Recommendation 3. 18
Recommendation 4— 19
Recommendation 5 20
Recommendation 6 21
Recommendation 7 22
Recommendation 8 — 23
Recommendation 9 24
Recommendation 10 25
iii
-------
U.S. Environmental Protection Agency
Science Advisory Board
401 M Street, S.W.
Washington, DC 20460
Relative Risk Reduction Strategies
Committee
Steering Committee
Co-Chainnen
Dr. Raymond Loehr
Professor of Civil Engineering
university of Texas
Austin, "fX
Dr. Jonathan Lash
Secretary of Natural Resources
for the State of Vermont
Waterbury, VT
Members
Mr. Alvin Aim
Vice President
Science Applications International
Corporation
McLean, VA
Dr. Betsy Ancker-Johnson
Vice President of the
Environmental Activities Staff
General Motors Corporation
Wanen, MI
Mr. Richard Conway
Senior Corooiate Fellow
Union Carbide Corporation
South Charleston, WV
Dr. William Cooper
Chairman of the Zoology Department
Michigan State University
East Lansing, MI
Dr. Anthony Cortese
Dean of Environmental Programs
Tufts University
Medford, MA
Dr. Paul Deisier
Visiting Executive Professor
University of Houston
Houston, TX
Mr. Fred Hansen
Director of the Department of Environmental
Quality for the State of Oregon
Portland, OR
Dr. Mortor. Lippmann
Professor of Environmental Medicine
New York University
Tuxedo, NY
Dr. Roger McQellan
President
The Chemical Industry Institute
of Toxicology
Research Triangle Park, NC
•Dr. Norton Nelson
Director Emeritus of the Institute of
Environmental Medidne
New York University
New York, NY
Dr. Arthur Upton
Director of the Institute of
Environmental Medicine
New York University
New York, NY
Designated Federal Official
Dr. Donald Barnes
Staff Director, Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C
Project Staff Coordinator
Mr. Frederick Alien
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington, D. C
Editors
Mr. Tom Super
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington. D. C
Mr. Steve Young
Science Advisory Board (On loan)
U. S. Environmental Protection Agency
Washington, D. C
Support Staff
Ms. Joanna Foellmer
Science Advisory Board
U. S, Environmental Protection Agency
Washington, D. C.
"Deceased
Ecology and Welfare
Subcommittee
Chairman
Dr. William Cooper
Chairman of the Zoology Department
Michigan State University
East Lansing, MI
Members
Dr. Yorum Cohen
Associate Professor of Chemical Engineering
University of California
at Los Angeles
Los Angeles, CA
Dr. Steve Eisenieich
Professor of Environmental Engineering
University of Minnesota
Minneapolis, MN
Dr. Mark Harwell
Director of Global Environmental Programs
Cornell University
Ithaca, NY
Dr. Dean Havnes
Professor of Entomology
Michigan State University
East Lansing, MI
Dr. Robert Huggett
Director of the Virginia Institute
of Marine Studies
College of William and Mary
Seaford, VA
Dr. Ronald Olsen
Professor of Microbiology and Associate
Vice President for Research
University of Michigan Medical School
Ann Arbor, MI
Dr.-Dave Reichle
Associate Director of Biomedical
and Environmental Sciences
Oak Ridge National Laboratory
Oak Ridge, TN
Dr. June Lindstedt-Siva
Manager of Environmental Science
Atlantic Richfield Company
Los Angeles, CA
iv
-------
Designated Federal Official
Mr. Robert Flaak
Science Advisory Board
U- S. Environmental Protection Agency
Washington, D. C
Strategic Options Subcommittee
Chairman
Mr. Ahrin Aim
Vice President
Science Applications
international Corporation
McLean, VA
Members
Dr. Betsy Ancker-Johnson
Vice President of Environmental
Activities Staff
General Motors Corn.
Warren, MI
Dr. Richard Andrews
Professor of Environmental Studiei
University of North Carolina
Chapel IM. NC
Richard Conwa<
mway
ite Fellow
Corpora
wi, WV
itkm
^nion
South Charleston,
Dr. Anthony Cortese
Dean of Environmental Programs
Tufts University
Madfard, MA
Dr. Roger Kasperson
Professor of Geography
Oark University
Worchester, MA
Dr. Henry Kelly'
Senior Assoaate
Office of Technology Assessment
U.S. Congress
Washington, D.C.
Dr. Paul R. Portney
Vice President
Resources for die Future
Washington, D.C.
Mr. William Ryan
Policy Director
National Environmental Law Center
Boston, MS
Ms. Nancy Seidman
Executive Director
Northeast States for Coordinated
Air Use Management
Boston, MA
Dr. Robert Stavins
Assistant Professor of Public Policy
John F. Kennedy School of Government
Harvard University
Cambridge, MA
Ms. Marcu Williams
Divisional Vice President
Environmental Policy and Planning
Browning-Ferns industries
Washington, D.C.
Designated Federal Officials
Dr. C. Richard Cothem and
Mrs. Kathleen Conway
Science Advisory Board
U. 5. Environmental Protection Agency
Washington, D. C.
Support Staff
Ms. DarieneSewdl
Science Advisory Board
U. S. Environmental Protection Agency
Washington, D. C
Human Health Subcommittee
Chairman
Dr. Arthur Upton
Director of the Institute of
Environmental Mediane
New York University
New York, NY
Member*
Dr. Julian B. Andehnan
Professor of Water Chemistry
University of Pittsburgh
Pittsburgh, PA
Dr. Patricia Buffler
Director of Epidemiological Research Unit
University of Texas
Houston, IX
Dr. Paul Dealer
Visiting Executive Professor.
University of Houston
Houston, Texas
Dr. Howard Hu
Assistant Professor of
Occupational Mediane
Brighsm It Women's Hospital
Harvard University Medical Center
Boston, MA
Dr. Nancy Kim
Director of the Division of
Environmental Health Assessment
New York Department of Health
Albany, NY
Dr. Morton Linpmann
Professor of Environmental Medicine
New York University
Tuxedo, NY
Dr. Roger McQellan
President
The Chemical Industry Institute
of Toxicology
Research Triangle Park, NC
Dr. Amo Motulsky
Professor of Medicine and Genetics
University of Washington School of Medicine
Seattle, WA
Dr. Frederics Peren
Associate Professor of Public Health
Columbia University
New York, NY
Dr. Jonathan Samet
Professor of Medicine
University of New Mexico
Albuqueique, NM
Dr. Ellen Silbergeld
Senior Scientist
Environmental Defense Fund
Washington, D.C.
Dr. Bernard Weiss
Professor of Toxicology
University of Rochester Medical Center
Rochester, NY
Dr. Hanspeter Witschi
Associate Director of the Toxics Program
University of California
Davis, CA
Designated Federal Official
Mr. Samuel Rondberg
Science Advisory Board
U. 5. Environmental Protection Agency
Washington, D. C
-------
Chapter One—Executive Summary
The Concept of Risk
Over the past 20 .years this country has put in place
extensive and detailed government policies to control
a number of environmental problems. Smog in
heavily populated areas, the eutrophication of lakes,
elevated levels of lead in the blooa of millions of
children, the threat of cancer from exposure to
pesticide residues in food, and abandoned drums of
hazardous wastes are a few of the problems that
have driven the enactment of more than a dozen
major Federal laws and the current public and
private expenditure of about $100 billion a year to
protect the environment.
Those efforts have led to very real national
benefits. The staggering human health and ecological
problems apparent throughout eastern Europe
suggest the price this country would be paying now
hadit not invested heavily in pollution controls.
Yet despite the demonstrable success of -past
national efforts to protect the environment, many
national environmental goals still have not been
attained. Factors like the growth in automobile use
and common agricultural practices have caused
national efforts to protect the environment to be less
effective than intended.
Furthermore, with hindsight it is dear that in
many cases those efforts have been inconsistent,
uncoordinated, and thus less effective than thev
could have been. The fragmentary nature of U.S.
environmental policy has been evident in three ways:
• In Laws. As different environmental problems were
identified,, usually because the adverse effects —
smog in major cities, lack of aquatic life in stream
segments, aedining numbers of bald eagles — were
readily apparent, new laws were passed to address
each new problem. However, the tactics and goals of
the different laws were neither consistent nor •
coordinated, even if the pollutants to be controlled
were the same. Many laws not passed primarily for
environmental purposes also had major effects on
the environment.
• In Programs. The Environmental Protection Agency
(EPA) was established as the primary Federal agency
responsible for implementing the nation's
environmental laws. EPA then evolved an
administrative structure wherein each program was
primarily responsible for implementing specific laws.
Consequently, the efforts of the different programs
rarely were coordinated, even if they were
attempting to control different aspects of the same
environmental problem. This problem is
compounded by the fact that EPA is not th$ only
agency whose activities affect the environment."
• In Tools. The primary tools used to protect the
environment have been controls designed to capture
pollutants before they escape from smokestacks,
tailpipes, or sewer outfalls, and technologies
designed to dean up or destroy pollutants after they
have been discharged into the environment. These
so-called "end-of-pipe" controls and remediation
technologies almost always have been applied
because of Federal, State,' or local legal requirements.
For a number of reasons, this kind of fragmented
approach to protecting the environment will not be
as successful in the future as it has been in the past.
In this country the most obvious controls already
have been applied to the most obvious problems. Yet
complex ana less obvious environmental problems
remain, and the aggregate cost of controlling those
problems one-by-one is rising.
Moreover, this country — and the rest of the
world — are facing emerging environmental
problems of unprecedented scope. Population
growth and industrial expansion worldwide are
straining global ecosystems. Never before in history
have human activities threatened to change
atmospheric chemistry to such an extent that global
climate patterns were altered.
Given the diversity, complexity, and scope of the
environmental problems of concern today, it is
aitically important that U.S. environmental policy
evolves in several fundamental ways. Essentially,
national policy affecting the environment must
become more integrated and more focused on
opportunities for environmental improvement than it
has been in the past.
The environment is an interrelated whole, and
society's environmental protection efforts should be
integrated as well. Integration in this case means tha
government agencies should assess the range of
environmental problems of concern and then target
protective efforts at the problems that seem to be the
most serious. It means tnat society should use all the
tools — regulatory and non-regulatory alike — that
are available to protect the environment. It means
that controlling the end of the pipe where pollutants
enter the environment, or remediating problems
caused by pollutants after they have entered the
environment, is not sufficient. Rather,
1
-------
waste-generating activities have to be modified to
minimize the waste or to prevent the waste from
being generated at all. Most of all, integration is
critically important because significant sources of
environmental degradation are embedded in typical
day-to-day personal and professional activities, the
cumulative effects of which can become serious
problems. Thus protecting the environment
effectively in the future will require a more broadly
conceived strategic approach, one that involves the
cooperative efforts or all segments of society.
One tool that can help foster the evolution of an
integrated and targeted national environmental
policy is the concept of environmental risk.Each
environmental problem poses some possibility of
harm to human health, the ecology, the economic
system, or the quality of human life. That is, each
problem poses some environmental risk. Risk
assessment is the process by which the form,
dimension, and characteristics of that risk are
estimated, and risk management is the process by
which the risk is reduced.
The concept of environmental risk, together with
its related terminology and analytical methodologies,
helps people discuss disparate environmental
problems with a common language. It allows many
environmental problems to be measured and
compared in common terms, and it allows different
risk reduction options to be evaluated from a
common basis. Thus the concept of environmental
risk can help the nation develop environmental
policies in a consistent and systematic way.
Scientists have made some progress in developing
quantitative measures for use in comparing different
risks to human health. Given sufficient data, such
comparisons are now possible within limits. •
Although current ability to assess and quantify
ecological risks is not as well developea, an increased
capacity for comparing different kinds of risks more
systematically would help determine which problems
are most serious and deserving of the most urgent
attention. That capacity would be even more valuable
as the number and seriousness of environmental
problems competing for attention and resources
increase.
An improved ability to compare risks in common
terms would have another value as well: it would
help society choose more wisely among the range of
policy options available for reducing risks. There are
a number of ways to reduce the automobile
emissions that contribute to urban smog; there are a
number of ways to decrease human exposure to lead.
The evaluation of relative risks can help identify the
relative efficiency and effectiveness of different risk
reduction options.
There are heavy costs involved if society fails to set
environmental priorities based on risk. If finite
resources are expended on lower-priority problems at
the expense of higher-priority risks, then societv will
face needlessly high risks. If priorities are established
based on the neatest opportunities to reduce risk,
total risk will be reduced in a more efficient wav,
lessening threats to both public health and local and
global ecosystems.
2
-------
The Traditional Role
of the Environmental
Protection Agency
For the past 20 years, EPA has been basically a
"reactive" agency. As environmental problems were
identified, the public conveyed its concern to
Congress, and Congress passed laws to try to solve
the problems within some, often well-defined,
timeframe. EPA then implemented the laws using
the resources — budget and staff — allocated by
Congress.
Consequently, EPA has seen its mission largely as
managing the reduction of pollution and. in
particular, only that pollution that is defined in the
laws that it adiininistets. EPA's internal programmatic
structure mirrors the environmental legislation that it
is required to implement. Moreover, the tools EPA
traditionally has used to reduce pollution have been
limited, in general, to the emissions controls it could
force polluters to apply through regulatory action.
This reactive mode, although understandable when
seen in its historical context, has limited the
efficiency and effectiveness of EPA's environmental
protection efforts. Because of EPA's tendency to react
to environmental problems defined in specific
environmental laws, the Agency has made little
effort to compare the relative seriousness of different
problems. Moreover, the Agency has made very little
effort to anticipate environmental problems or to take
preemptive actions that reduce the likelihood of an
environmental problem occurring.
Because most of EPA's program offices have been
responsible for implementing specific laws, they have
tended to view environmental problems separately;
each program office has been concerned primarily
with those problems that it has been mandated to
remediate, and questions of relative seriousness or
urgency generally have remained unasked.
Consequently, at EPA there has been little correlation
between the relative resources dedicated to different
environmental problems and the relative risks posed
by those problems.
3
-------
Unfinished Business
The Environmental Protection Agency squarely faced
the question of relative risk for the first time when it
established an Agency task force to assess and
compare the risks associated with a range of
environmental problems. In 1986 and 1987, about 75
senior career managers and staff compared the
relative risks posed by 31 environmental problems
within four broad categories of risk: 1) human cancer
risk, 2) human non-cancer health risk, 3) ecological
risk, and 4) welfare risk. The task force limited its
comparison to those risks that remain after
currently-required controls have been applied (i.e.,
residual risks). The results of this effort were
presented in Unfinished Business: A Comparative
Assessment of Environmental Problems.
Unfinished Business was a landmark study. For die
first time, the many environmental problems of
concern to EPA were compared to each other in a
non-programmatic context Moreover, the report
expliatly pointed out the disparity between residual
risk ana resource allocation at EPA. The problems
that the authors judged to pose the most serious
risks were not necessarily the problems that
Congress and EPA had targeted for the most
aggressive action.
However, the report did find a correlation between
EPA's programmatic priorities and the apparent
public perceptions of risk. That is. Congress and the
Agency were pavine the most attention to
environmental problems that the general public
believed posed the greatest risks.
The authors of Unfinished Business recognized that
their risk rankings, while based on the judgments of
experienced professionals, were limited, since they
were based on incomplete data and novel risk
comparison techniques. But the value of the report,
then and now, rests not so much on the accuracy of
the rankings but on the fact that EPA had begun to
see the long-term public policy importance of
understanding relative risks, m short. Unfinished
Bustness was vet another sign that the nation as a
whole, and EPA in particular, could not continue
"business-as-usual" in the face of the environmental
risks of the 1990s and beyond.
4
-------
The Relative Risk
Reduction Strategies
Committee
Shortly after he took office early in 1989, EPA
Administrator William K. Reilly asked the Science
Advisory Board (SAB) to. review EPA's 1987 report
on relative environmental risk. Unfinished Business,
evaluate its findings, and develop strategic options
for reducing risk. In response to that reouest, the
SAB formed a special committee, the Relative Risk
Reduction Strategies Committee (RRRSQ, which in
turn was divided into three Subcommittees: the
Ecology and Welfare Subcommittee, the Human
Health Subcommittee, and the Strategic Options
Subcommittee.
The Relative Risk Reduction Strategies Committee
was co-chaired by Dr. Raymond C. Loehr, chairman
of the SAB and professor at the University of Texas,
and Mr. Jonathan Lash, Secretary of the State of
Vermont's Agency of Natural Resources. The Ecology
and Welfare subcommittee was chaired by Dr.
William Cooper of Michigan State University; the
Human Health Subcommittee was chaired by Dr.
Arthur Upton of the Institute of Environmental
Medicine, New York University Medical Center, and
the Strategic Options Subcommittee was chaired by
Mr. Alvin Aim of Science Applications International
Corporation.
Tne 39 members of the RRRSC and its
Subcommittees were nationally-recognized scientists,
engineers, and managers with broad experience in
addressing environmental and health-issues. Their
names ana professional affiliations are listed at the
front of this overview report
Through its combined efforts the RRRSC attempted
to achieve four objectives:
1. Critically review Unfinished Business, reflecting any
significant new information that bears on the
evaluation of risks associated with specific
environmental problems.
2. To the extent possible, merge die evaluations of 1)
cancer and non-cancer risks and 2) ecological and
welfare risks.
3. Provide optional strategies for reducing the major
environmental risks.
5
4. Develop a long-term strategy for improving the
methodology for assessing and ranking
environmental risks and for assessing the alternative
strategies that can reduce risks.
In particular, the Ecology and Welfare
Subcommittee and the Human Health Subcommittee
were charged with reviewing and updating the risk
findings from Unfinished Business. Those two
Subcommittees were to provide, to the extent
possible, a single aggregate ranking of the risks that
each Subcommittee assessed, and recommend a
long-term strategy for improving the methodology
for assessing such risks, the Strategic Options
Subcommittee was charged with 1) identifying
strategy options for reducing residual environmental
risks, and 2) developing and demonstrating analytical
methodologies for identifying and selecting risk
reduction options.
The RRRSC began planning its work in the spring
of 1989, and it held its first meeting in September
1989. In all, the Committee and its three
Subcommittees held twelve public meetings and
three working sessions.
The RRRSC has conducted a lengthy review
data and methodologies that support risk
assessment, comparison, and reduction today. iiu»
review of environmental risk has led to several
conclusions about the need for and value of
comparative risk assessments and their implications
for the national environmental agenda.
This overview report highlights the most important
findings and recommendations from the three
Subcommittee reports, along with insights derived
from discussions among the Committee members
after they reviewed the Subcommittee reports. The
full reports of the three Subcommittees are included
as appendices to this report (see inside back cover)
and snould be referred to for important additional
information and detailed support for the contents of
this overview report.
The RRRSC recognizes that this overview report
and its appendices contain policy-oriented findings
and recommendations that are outside the normal
scope of SAB purview. But in this case the EPA °
Administrator explicitly asked the SAB to review,
from a technical and scientific perspective, the
optional strategies available for reducing risk. Thus
this report includes recommendations on approaches
to risk management and on the future direction of
national environmental policy. However, nothing in
this report or its appendices should be construed as
an SAB recommendation for a specific policy option
to be used to reduce a specific environmental nsk.
-------
The Ten
Recommendations
1. EPA should target its environmental protection
efforts on the basts of opportunities for the greatest
risk reduction. Since this country already has taken
die most obvious actions to address the most obvious
¦ environmental problems. EPA needs to set priorities
for future actions so the Agency takes advantage of
the best opportunities for reducing the most serious
remaining rides.
2. EPA should attach as much importance to
reducing ecological risk as it does to reducing
human health risk. Because productive natural
ecosystems are essential to human health and to
sustainable, long-term economic growth, and because
they are intrinsically valuable in their own right, EPA
should be as concerned about protecting ecosystems
as it is about protecting human health.
3. EPA should improve the data and analytical
methodologies that support the asseslatent,
comparison, and reduction of different
environmental risks. Although setting priorities for
national environmental protection efforts always will
involve subjective judgments and uncertainty, EPA
should work continually to improve the scientifc data
and analytical methodologies that underpin those
judgments and help reduce their uncertainty.
4. EPA should reflect xisk*based priorities in its
strategic planning processes. The Agency's
long-range plans should be driven not so much by
past risk reduction efforts or by existing
programmatic structures, but by ongoing
assessments of remaining environmental risks, the
explicit comparison of those risks, and the analysis of
opportunities available for reducing risks.
5. EPA should reflect iisJc«based priorities in Its
budget process. Although EPA's budget priorities are
determined to a large extent by the different
environmental laws that the Agency implements, it
should use whatever discretion it has to focus budget
resources at those environmental problems that pose
the most serious risks.
6. EPA — and the nation as a whole — should make
greater use of all the tools available to reduce risk.
Although the nation has had substantial success in
reducing environmental risks through the use of
government-mandated end-of-pipe controls,.the
extent and complexity of future risks will necessitate
the use of a much broader array of tools, including
market incentives and information.
7. EPA should emphasize pollution prevention as
the preferred option tor reducing risk. By
encouraging actions that prevent pollution from
being generated in the fust place, EPA will help
reduce the costs, intermedia transfers of pollution,
and residual risks so often associated with
end-of-pipe controls.
8. EPA should increase its efforts to integrate
environmental considerations into broader aspects of
public policy in as fundamental a manner as are
economic concerns. Other Federal agencies often
affect the quality of the environment, e.g., through
die implementation of tax, energy, agricultural, and
international policy, and EPA should work to ensure
that environmental considerations are integrated,
where appropriate, into the policy deliberations of
such agencies.
9. EPA should work to improve public
understanding of environmental risks and train a
professional workforce to help reduce them. The
improved environmental literacy of the general
public, together with an expanded and better-trained
technical workforce, will be essential to the nation's
success at reducing environmental risks in the future.
10. EPA should develop improved analytical
methods to value natural resources and to account
for long-term environmental effects in its economic
analyses. Because traditional methods of economic
analysis tend to undervalue ecological resources and
fail to treat adequately questions of intergenerational
equity, EPA should develop and implement
innovative approaches to economic analysis that will
address these shortcomings.
6
-------
Chapter Two—Findings
1. The Importance of
Unfinished Business
' ' ; With the publication of Unfinished Business early in
H-3.0; H-6JD' 1987, EPA took a bold and much-needed step: it
E-3J); E-5i)' compared the relative residual risks posed by a range
g-4_2 ¦ of different environmental problems, and thus
• suggested an important shut in national
—. ¦¦ n environmental policy. With that report EPA took the
first step toward relative risk reduction; that is, a
policy that attempts to match Agency and societal
resources to risk.
To produce Unfinished Business EPA brought
together staff from all its program offices for the
explicit purpose of comparing the relative risks of
different environmental problems, regardless of
individual programmatic priorities or responsibilities.
To do that, the EPA staff had to assess
environmental risk in a context broader than
programmatic structure or legislated activities. In
short, they had to put aside considerations of
bureaucratic "turf in order to rank the problems
they believed most needed society's attention. EPA
should be applauded for the courage and foresight to
undertake a project like Unfinished Business.
Unfinished Business presents useful, preliminary
information for comparing environmental problems,
although in some eases its rankings are a nutter of
judgment and cannot be supported fully by existing
data. The Ecology and Welfare Subcommittee
questioned the welfare rankings, because it disagreed
with some of the economic assumptions underlying
those rankings and because of a general lack of
relevant economic data. The Human Health
Subcommittee questioned die accuracy of any
ranking of human health risks at this time, given the
limited human exposure and chronic toxicity data
currently available. Both Subcommittees observed
that the 31 problems assessed were not derived from
a systematic classification of all environmental
problems, and both suggested alternative and more
comprehensive approaches to classification that
would facilitate a more coherent ranking.
Most of the 31 environmental problems assessed in
Unfinished Business are so broad, and include so many
toxic and non-toxic agents, that its ranking of
problems cannot be evaluated with rigor or -
confidence. Additionally, the authors of Unfinished
Business intentionally defined environmental
problems to correspond to legislation and
programmatic organization. As a result, they
attempted to compare heterogenous mixtures of
pollutants (like air pollutants and drinking water
pollutants) to pollutant sources (like oil spills and
mining waste) to receptors (like consumers and
workers). Yet without a consistent basis for
comparison, such comparisons are tenuous at best.
Moreover, because the authors chose to limit the
environmental problems they compared. Unfinished
Business does not address problems like the loss of
habitat and the dedine in genetic diversity, even
though such problems pose very serious risks,
EPA and other agencies may be able to take a
to mitigate them. A meaningful ranking of rela.
environmental risks must include all such risks,
whether or not lam have been passed or programs
set up to control them.
A final shortcoming for the authors of Unfinished
Business was die availability of data. Good oata to
evaluate risks simply did not — and in many cases
still do not — exist. The EPA staff understandably
used their professional judgment to fill the data
gaps. The Subcommittee reports appended to this
overview, report document in more detail the
members' judgments as to the relative strength and
weakness of the data used to support the risk
rankings in Unfinished Business.
The findings and recommendations described in this overview report have been derived mainly from the reports prepared
by the three Subcommittees of the Relative Risk Reduction Strategies Committee. Those reports, which are included as
appendices to this report, contain detailed information that support and more fully explain the findings and
recommendations. Such information can be found by referring to the sections of the different appendices that are listed at
the beginning of each finding and recommendation. In the listed oossieferences:
• "E" refers to the Report of the Ecology and Welfare Subcommittee;
• "H" refers to the Report of the Human Health Subcommittee; and
• *S" refers to the Report of the Strategic Options Subcommittee.
7
-------
2. Problems in
Ranking Risk$
E-3.0; E-S2
H-34J? H-6JD
As long as there are large gaps in key data sets,
efforts to evaluate risk on a consistent, rigorous basis.
or to define optimum risk reduction strategies
necessarily wuJ be incpmplete, and the results will be
uncertain. For example, data on human exposure
and on the toxicity of many pollutants are seriously
deficient In particular, the lack of pertinent exposure
data makes it extremely difficult to assess human
health risks.
Moreover, great uncertainty often is associated
with the data that do exist. Exposure and toxic
response models, the numbers used to quantify
risks, and variations in individual susceptibility to
ri«ks are often highly uncertain. Without more and
better data, conclusions about relative risk will be
tenuous and will depend in large measure on
professional judgment.
In addition to the lack of data, methodological
inadequacies also impede the assessment and
comparison of risk. At this time EPA does not have
an effective, consistent way of identifying
environmental problems in a manner that neither
fragments nor aggregates sources of risk to an extent
that renders comparisons untenable. EPA's current
framework of statutory mandates and program
structure helps to maintain artificial distinctions
among environmental problems, and those
distinctions are conducive neither to sound
evaluation of relative risk nor to selection of the mo?t
effective actions to reduce risk.
In particular, the methodologies currently used to
estimate the benefits of risk reduction activities are
inadequate and inappropriate. For example, a
methodology that presumes the future value of an
ecological resource necessarily must be less than its
present value will not be a useful analytical tool for
sustaining economic development over the long
term. The standard practice of discounting future
resource values is inappropriate, and it results in
policies that lead to the depletion of irreplaceable
natural resources.
Reliance on "willingness to pay" and similar
techniques commonly used in economic analyses has
distorted current understanding of the value of'
natural resources. While some people may not care
about wetlands and assign no value to their
existence, such areas still provide valuable ecosystem
services to this and future generations. While few
people are likely to care about and be willing to pay
for plankton and fungi, such organisms play a critical
role in sustaining economically valuable ecosystems.
An additional difficulty entailed in any attempt to
compare and rank environmental risks is the
inevitable value judgments that must be made. For
example, are health risks posed to the aged more or
less serious than health risks posed to infants? Are
risks of cancer more or less serious than threats to
reproductive processes? Comparing the risks posed
to human populations with the risks posed to
ecosystems may be even more difficult. It seems clear
that subjective values always will — and should —
influence the ranking of relative environmental risks,
no matter how sophisticated the technical and
analytical tools become.
8
-------
3. The Extraordinaiy
Value of Natural
Ecosystems
Natural ecosystems like forests, wetlands, and
E<5£ oceans are extraordinarily valuable. Those
i ecosystems contain economically valuable natural
— resources that feed, dothe, and house the human
nee. They act as sinks that, to a certain extent,
absorb and neutralize the pollutants generated by
human activity. Although natural ecosystems — and
the linkages among them — are not completely
understood, there is no doubt that over time the
quality of human lift declines as the quality of
natural ecosystems declines.
The value of natural ecosystems is not limited to
their immediate utility to humans. They have an
intrinsic, moral value that must be measured in its
own terms and protected for its own sake.
However, over the past 20 years and especially
over the past decade, &PA has paid too little
attention to natural ecosystems. The Agency has
considered the protection of public health to be its
primary mission, and it has been less concerned
about risks posed to ecosystems. The Agency's
relative lack of concern reflects society's views as
expressed in environmental legislation; ecological
degradation probably is seen as a less serious
problem because it is often subtle, long-term, and
cumulative. But for whatever reason, tnis imbalance
is a manifest, if inadvertent, part of current national
environmental policy.
EPA's response to human health risks as compared
to ecological risks is inappropriate, because, in tke
real world, there is little distinction between the two.
Over the long term, ecological degradation either
directly or indirectly degrades human health and the
economy. For example, as the extent and quality of
saltwater estuaries decline, both human health and
local economies can suffer. As soils erode, forests,
farmlands, and waterways can become less
productive. And while tne loss of species may not be
noticed immediately, over time the decline in genetic
diversity has implications for the future health of the
human race.
In short, human health and welfare ultimately rely
upon the life support systems and natural resources
provided by healthy ecosystems. Moreover, human
beings are part of an interconnected and
interdependent global ecosystem, and past
experience has shown that change in one part of the
system often affects other parts in unexpected wavs-
National efforts to evaluate relative environmental
risks should recognize the vital links between human
life and natural ecosystems. Up to this point, they
have not.
9
-------
4. Time, Space,
and Risk
E-4.3; E-7J0
S-Z2
While the data needed to support firm rankings of
risk were found to be limited, the RRRSC identified a
number of important factors that must be considered
in any assessment or ranking of the risk associated
with a particular environmental problem. Those
factors include the number of people and other
organisms exposed to the risk, the likelihood of the
environmental problem actually occurring among
those exposed, and the severity of the effects,
including the economic losses and other damages
involved^ if it does occur.
In addition, two other aspects of potential
environmental problems — i.e., their temporal and
spatial dimensions — also must be given
considerable weight in any analysis of relative
environmental risk. Consideration of time and space
can help guide judgments about relative risks in the
absence of complete data.
The temporal dimension of an environmental
problem is the length of time over which the
problem is caused, recognized, and mitigated. For
some environmental problems the temporal
dimension can be very long. For example, the
chronic human health effects of air or water pollution
may become apparent only after many years of
exposure. It may take decades of human activity to
begin to change the global climate, and more decades
may pass before the effects of human activity on die
global climate are clearly understood. Some
pollutants can persist in the environment — and thus
pose environmental risks — indefinitely. And it may
take decades or even centuries before depleted
species of wildlife recover from the loss of habitat, if
recovery is possible at all.
The spatial dimension of an environmental
problem is the extent of the geographical area that is
affected by it. Some environmental problems, like
elevated levels of radon, may be limited to the
basements of some homes, while problems like
stratospheric ozone depletion can affect the entire
globe. And some global problems, like the loss of
genetic diversity, can be caused by human activities
in relatively limited geographical areas.
The time and space dimensions of environmental
problems should weigh heavily in any comparison of
relative environmental risks. For example, if
long-lived pollutants like DDT and PCds can become
concentrated in the food chain and pose a threat to
future as well as present human and ecological
health, those future risks should be taken into
account when relative risks are compared. Similarly,
if global climate change or stratospheric ozone
depletion has the potential to affect the health and/or
economic well-being of virtually everyone on earth,
now and in the future, the extent and duration of the
risk should suggest a relatively high-risk ranking.
Ecosystems are generally resilient to short-term
insults. For example, oil spills and water pollution
usually cause only temporary ecological cnanges;
nature has a substantial capacity for healing itself.
However, some changes are either permanent or
semipermanent. Destroying wetlands, altering
natural water flows (as in me Everglades), global
wanning, and stratospheric ozone depletion can
cause irreversible ana, in some cases, widespread
problems.
In fact, some long-term and widespread
environmental problems should be considered
relatively high-risk even if the data on which the risk
assessment is based are somewhat incomplete and
uncertain. Some risks are potentially so serious, and
the time for recovery so long, that risk reduction
actions should be viewed as a kind of insurance
premium and initiated in the face of incomplete and
uncertain data. The risks entailed in postponing
action can be greater than the risks entailed in taking
inefficient or unnecessary action. Moreover,
preemptive actions are especially justifiable if — like
the energy conservation efforts that would slow the
accumulation of greenhouse gases — they lead to
unrelated but immediate and substantial benefits,
such as improved ambient air quality and reduced
U.S. dependence on imported oil.
10
-------
5. The links Between
Risk and Choice
It is sometimes tempting to think simplistically about
S-12 the sources of environmental risk as being a
; particular industry, a particular product, or a
-- - j particular pollutant. Conceptually, smokestacks can
be controlled, products modified, and pollutants
banned with relative ease.
But the sources of environmental risk are much
more diverse and complicated than that. In fact, the
sources of risk often are to be found in the
day-to-day choices made by individuals,
communities, and businesses. And many kinds of
environmental risk will not be reduced substantially,
especially over the long term, if past patterns of
individual, community, and business choices do not
change in light of the relative risks posed by those
choices.
In a sense, die very existence of the human race
inevitably poses some level of environmental risk.
People necessarily generate wastes, both as
individuals and through aggregate economic
activities. People necessarily destroy or infringe upon
some natural Habitats when they construct their own.
Individuals either increase or lessen environmental
risk depending on which consumer products they
buy, how they design their homes, and whether they
walk or drive to work. Society affects environmental
risk at the local' level through' building codes and
zoning laws and at the national level through tax,
. energy, and agricultural polides.
But all these activities involve choice, and the
environmental risks posed bv many human activities
can be reduced sharply if different choices are made.
So one of the most important questions faang soaety
is how to influence and shape individual,
community, and-business choices so that
environmental risks are reduced.
Choice is influenced by a number of factors,
including education and'ethics. Some people may
choose to purchase certain consumer proaucts
because of a genuine concern about the
environmental effects of their personal buying
patterns. Similarly, some businesses may redesign
production processes to eliminate pollution because
of a desire to be perceived as corporate "good
citizens."
Economic incentives are also important tools for
inducing particular kinds of choices. When the price
of energy rises, consumers are likely to buy more
fuel-efficient vehicles and weatherize their homes,
while plant managers have an added incentive to
purchase more energy-efficient equipment. Full
pricing of municipal services can give people an
incentive to recycle their household wastes and
conserve water.'
Laws and regulations, of course, are very effective
at shaping individual and social choices. Local
zoning laws can change the pattern of economic
development in a community and limit where homes
can be built. Local, State, anci Federal procurement
regulations can have a substantial effect on the
development of markets for recycled products.
Projected future growth in population and
economic activity could add enormously to the
environmental risks faced in this country and around
the world. But growth and reductions in
environmental risk are not necessarily incompatible,
if past patterns of individual, community, and
business choice can change. In national efforts to
assess, compare, and control relative risks, the
importance of those choices — and the policy option
available to influence those choices — should not be
overlooked.
11
-------
6. Public Perceptions
of Risk
"" *" public opinion polls taken over the past several years
c»d confirm that people are more worried about
environmental problems now than they were 20
¦ years ago when the first wave of environmental
concern led to major changes in national policy. But
the areas of greatest concern to the public today are
not necessarily those problems identified in
Unfinished Business. In other words, the remaining
and emerging environmental risks considered most
serious by the general public today are different from
those considered most serious by the technical
professionals charged with reducing environmental
risk.
This dichotomy between public perceptions and
professional understanding of environmental risk
presents an enormous dumenge to a pluralistic,
democratic country. A Federal agency like EPA must
be sensitive to public concents about environmental
problems. In fact, since public concerns tend to drive
national legislation. Federal environmental laws are
more reflective of public perceptions of risk than of
scientific understanding of risk. Consequently, EPA's
budget and staff resources tend to be directed at
those environmental problems perceived to be most
serious by the general public.
Yet if national resources are to be used most
effectively to promote environmental quality, then
such resources must be aimed at those '
environmental problems that pose the greatest risks.
The ability to match resources to risks will measure
the success of national policies to protect the
environment.
One obvious way to bridge this dichotomy would
be to improve the public's understanding ot the
scientific and technical aspects of environmental risk
while improving scientists' understanding of the
basis of public concern. Public perceptions of
environmental risk tend to incorporate deeply-held
subjective values, like justice ana equity, that,
although difficult to quantify, reflect important
elements of the quality of life that government is
bound to protect. Moreover, since the scientific
understanding of any environmental problem is
likely to evolve as the science improves, and since
environmental policy necessarily embodies subjective
values, scientific understanding should not be the
sole determinant of environmental policy.
Therefore, EPA must be prepared to listen
carefully to the public's perceptions of risk.
Moreover, EPA should balance those perceptions
with current scientific understanding as the Agency
develops long-term risk reduction strategies.
12'
-------
7. Relatively High-Risk
Environmental Problems
E-4Jfc E-6J;
H-SjQ; H-7J0
The RRRSC not only reviewed the risk rankings
contained in Unfinished Business, but it also identified
several environmental problems as relatively
high-risk, based on available scientific data and
technical understanding. This effort was challenging
for a number of reasons. Ecological, health, and
welfare risks can be manifested^ in a number of
different endpoints; it is difficult to compare risks
with widely aifferent time scales and spatial
dimensions; because of data gaps and methodological
inadequacies, it is rarely feasible to quantify total
risk. In other words, the RRRSC faced many of the
same hurdles that faced the authors of Unfinished
Business when they developed their risk rankings.
Consequently, the RRRSC did not rank risks in th
same manner as Unfinished Business did. The Ecolog,
and Welfare Subcommittee grouped environmental
problems into high-, medium-, and low-risk areas;
the Human Health Subcommittee identified
environmental problem areas where existing data
indicated that nsks could be relatively high.
Additional data might identify additional high-risk
problems. Both Subcommittees developed their
assessments in light of the latest scientific and
technical knowledge and using their best professioru
judgment, and both caution that their assessments
are based on incomplete and often inadequate
knowledge about 1) the extent of human and
ecological exposures to pollutants and 2)
exposure-response relationships.
Risks To The Natural Ecology And Human Welfare
The Ecology and Welfare Subcommittee identified areas
of relatively high, medium, and low risk, despite caps
in the relevant data. The four environmental problems
that it considered to be relatively high-risk are likely to
be considered high-risk even after data and analytical
methodologies are improved, because the geographic
scale of all lour is very large (regional to global), and
because die time that could be required to initiate all
four is very long, and some effects are irreversible.
The Ecology and Welfare Subcommittee did not limit
their assessment to the environmental problems listed
in Unfinished Business. The order of problems listed
within each of the three different risk groups shown
below is not meant to imply a ranking.
Relatively High-Risk Problems
• Habitat Alteration and Destruction
Humans are altering and destroying natural
habitats in many places worldwide, e.g., by the
draining and degradation of wetlands, soil
erosion, and the deforestation of tropical and
temperate rain forests.
• Species Extinction and'Overall Loss of Biological
" Diversity
Many human activities are causing species
extinction and depletion and the overall loss of
biological diversity, including the genetic diversity
of surviving species.
• Stratospheric Ozone Depletion
Because releases of chlorofluorocarbons and other
ozone-depleting gases are thinning the earth's
stratospheric ozone layer, more ultraviolet
diine the e
¦Stressing many kinos of organisms.
-radiation is reaching the earth's surface, thus
• Global Qimate Change
Emissions of carbon dioxide, methane, and other
greenhouse gases are altering the chemistry of the
atmosphere, threatening to cnange the global climate.
Relatively Medium-Risk Problems
• Herbicides/Pesticides
• Toxics, Nutrients, Biochemical Oxygen Demand, and
Turbidity in Surface Waters
• Add Deposition
• Airborne Toxics
Relatively Law-Risk Problems
• Oil Spills
• Groundwater Pollution
• Radionuclides
• Acid Runoff to Surface Waters
• Thermal Pollution
13
-------
Risks To Human Health
The Human Health Subcommittee limited its
assessment to those problems addressed by Unfinished
Business. On reviewing the rankings in Unfinished
Business, the Subcommittee identified those problems
that represented major types of human exposure
known to be associated with significant impacts on
human health. In four such instances, relatively
high-risk rankings were supported more firmly by the
available data than they were for other health problems.
The Subcommittee also noted that the development of
better methodologies and more complete data could
\m»A to a different approach to the assessment of human
health risks, and that such an approach would involve
the selection of specific environmental toxicants that
warranted detailed assessment and major risk reduction
efforts.
• Ambient Air Pollutants
Stationary and mobile sources emit a range of
different air pollutants to which large populations
are exposed. Some have toxic and/or carcinogenic
effects following direct inhalation exposure (e.g.,
carbon monoxide and benzene). Others, such as
lead and arsenic, reach humans by a variety of
pathways including direct inhalation, inhalation of
resuspended dust, and ingestion of dust deposited
on food products. StQl others are important
precursors that can lead to compounds such as
ozone, add aerosols, and carcinogenic
hydrocarbons that form in the atmosphere over
large areas of North America.
• Worker Exposure to Chemicals in Industry and
Agriculture
Industrial and agricultural workers are exposed to
many toxic substances in the workplace. Such
exposures can cause cancer and a wide range of
non-cancer health effects. Due to the large
population of workers directly exposed to a range
of highly toxic chemicals, this problem poses
relatively high human health nsks.
• Pollution Indoors
Building occupants may be exposed to radon and
its decay products as well as to many airborne
combustion products, including nitrogen dioxide
and environmental tobacco smoke. Indoor
exposures to toxic agents in consumer products
(e.g., solvents, pesticides, formaldehyde) also can
cause cancer ana a range of non-cancer health
effects. Due to the large population directly
exposed to a number of agents, some of which are
highly toxic, this problem poses relatively high
human health risks.
• Pollutants in Drinking Water
Drinking water, as delivered at the tap, may
contain agents such as lead, chloroform, and
disease-causing microorganisms. Exposures to
such pollutants in drinking water can cause cancer
and a range of non-cancer health effects. This
problem poses relatively high human health risks,
because large populations are exposed directly to
various agents, some of which are highly toxic
Other problem areas also involve potentially
significant exposure of large populations to toxic
chemicals; e.g., pesticide residues on food and toxic
chemicals in consumer products. However, the data
bases to support those concerns are not as robust as
they are for the four areas listed above.
14
-------
8. Strategy Options for
Reducing Environmental Risk
^ addition to reviewing the findings of Unfinished
S-4.4 Business, the RRRSC also reviewed a broad spectrum
of policy options available for reducing major
! environmental risks. The Strategic Options
Subcommittee examined a series of environmental
problems and identified a range of risk reduction
options for each of them. Thirteen problems were
included in the analysis, nine of which had been
ranked high in Unfinished Business.
The Subcommittee identified six generic risk
reducrion tools that should be considered for any
problem area (see box on the following page), and
generated 60 specific examples of options that could
Be applied to 13 environmental problems. The
Subcommittee also developed a series of criteria that
can be used to select from among the various risk
reduction options available. These criteria include the
magnitude of risk reduction to be achieved, the
likelihood of achieving that risk reduction, the costs
involved, the ease and speed of implementation and
enforcement, the degree of intermedia transfer of
risk, and overall cost-effectiveness.
Optional Tools For Reducing Environmental Risk
• Scientific and Technical Measures
Two major sets of scientific and technical measures are:
1) research and development to improve understanding
of problems and point to promising solutions; and 2)
innovations in pollution prevention approaches and
pollution control technology. Examples include
additional research to unoexvtand tne potential for
global wanning and development of ecologically
protective, co«t*«ffective technologies to manage
contaminated sediments.
• Provision of Information
In many eases risk reduction can be promoted by
providing information to producers, consumers, and/or
State ana local governments. For .example, new home
buyers could be provided with the results of radon
tests, and state and local governments could be
provided with technical information to help them
address indoor air pollution.'
• Market Incentives
A key to reducing environmental risk is to ensure that
consumers and producers face the full costs of their
decisions. Economic incentive systems often can help
accomplish this end. The major categories of incentive
systems include: 1) pollution charges, 2) marketable
permits, 3) deposit-refund systems, 4) removal of
market barriers, and 5) revision of legal standards of
liability. Examples include using marketable permits to
lower costs and spur innovation in reducing acid rain,
and creating deposit-refund systems for tires and
batteries.
• Conventional Regulations
Conventional regulations include performance
standards, design standards, use restrictions, and
product specifications. For example, the Agency coula
tighten restrictions on some uses of pesticides and
develop new standards for automobile emissions.
• Enforcement
In many cases substantial gains can be made ix.
environmental risk reduction by more vigorously
enforcing existing statutes and regulations, particularly
by employing innovative enforcement methods.
Options, include using statistical techniques for
enforcement to assure that all' classes ox potential
viola tore will be inspected, and assuring that penalties
aeate an incentive to comply with environmental laws.
• Cooperation With Other Government
Agencies and Nations
Many types of government policies affect the
environmental problems that EPA must address. Due to
EPA's limited jurisdiction, cooperation with other
agencies and nations often presents the best
opportunities to reduce certain kinds of environmental
risk. For example, the Agency could seek an
international convention on global wanning and an
agricultural policy that would reduce non-point source
pollution.
15
-------
Chapter Three—Recommendations
EPA Should Target Its Environmental Protection
Efforts On The Basis Of Opportunities For The
Greatest Risk Reduction
S-4J
Seen in its historical context, the ad hoc development
of U.S. national environmental policy is
understandable. Yet 20 years of experience in
developing and implementing environmental policy
~ has demonstrated that not all environmental
problems are eaually serious, and not all remediation
efforts are equally urgent. The nation cannot do
everything at once. In national efforts to protect the
environment, the most obvious steps have been
taken to reduce the most obvious nsks. Now
environmental priorities must be set.
In order to set priorities for reducing
environmental risks, EPA must weigh the relative
risks posed by different environmental problems,
determine if there are cost-effective opportunities for
reducing those risks, and then identify the most
cost-effective risk reduction options, this effort
should build on the analytical process begun in
Unfinished Business and in this report and its
appendices.
However, the SAB recognizes that risk analyses
always will be imperfect tools. No matter how much
the aata and methodologies are improved, EPA's
decisions to direct specific actions at specific risks
will entail a large measure of subjective judgment.
Yet the SAB believes that relative risk data and ride
assessment techniques should inform that judgment
as much as possible. In short, EPA programs should
be shaped and guided by the prindole of relative risk
reduction, and all available risk data and the most
advanced risk assessment and comparison
methodologies should be incorporated explicitly into
the Agency's decisionmaking process.
In order to implement a risk-based action agenda,
EPA must take several essential steps. It must
articulate to its own employees and to the general
public the fact that it intends to set priorities for
action based on opportunities for relative risk
reduction. Next the Agency must establish an explicit
Erocess for incoiporating those considerations into its
ing-term planning and budget processes. Finally,
the Agency must act on those priorities.
In practice, of course, EPA's activities are defined
by the laws that it is required to administer. EPA
also has a responsibility to respond to public
concents about an environmental problem, no matter
how limited the risk may seem to be. However.EPA
should not limit its risk comparison efforts to those
environmental problems it is required bv law to
mitigate. The risks posed by other problems and
potential problems — like the loss of biological
diversity — must be compared and ranked as well.
Simply stated, EPA is responsible for protecting
the environment, not just for implementing
environmental law. Thus the Agency should assess
and compare the universe of environmental risks and
then take the initiative to address the most serious
risks, whether or not Agency action is required
specifically by law.
16
-------
2. EPA Should Attach As Much Importance To
Reducing Ecological Risk As It Does To Reducing
Human Health Risk
.... .. .—Largely because of the requirements of the laws it
E_4jj • administers, EPA has tended to pay far more
attention to protecting human health and welfare
. \ than to protecting the ecology. Indeed, during the
1980s EPA's agenda was dominated by concerns
about the effects of toxic chemicals on human health.
Yet from the perspective of risk there are strong
linkages between human health and the health of
wetlands, forests, oceans, and estuaries. Most
human activities that pose significant ecological risks
— for example, the effects of agricultural activities on
wetlands — pose direct or indirect human health
risks as well. Likewise, actions taken to reduce
pollution and thus improve human health usually
improve various aspects of ecological quality.
These very , close linkages between human health
and ecological health should be reflected in national
environmental policy. When EPA compares the risks
posed by different environmental problems in order
to set priorities for Agency action, the risks posed to
ecological systems must be an important part of the
. equation.
This recommendation is not meant to imply the
relative value of human life wis a vis plant or animal
life. Rather, it is meant to reflect in national
environmental policy the very strong ties between all
forms of life on this planet. Ecological systems like,
the atmosphere, oceans, and wetlands have a limited
capacity for absorbing the environmental degradation
caused by human activities. After that capacity is
exceeded, it is only a matter of time before those
ecosystems begin to deteriorate and human health
and welfare begin to suffer.
In short, beyond their importance for protecting
Elant and animal life and preserving biodiversity,
ealthy ecosystems are a prerequisite to healthy
humans and prosperous economies. Although
ecological damage may not become apparent for
years, society should not be blind to tne fact that
damage is occurring and the losses will be felt, sooner
or later, by humans. Moreover, when species and
habitat are depleted, ecological health may recover
only with great difficulty, 3 recovery is possible at
Thus EPA's risk-based priorities for action should
reflect an appropriate balance between ecological,
human health, and welfare concerns. Furthermore,
the Agency should communicate to the genera'
public a clear message that it considers ecologi
risks to be just as serious as human health and
welfare risks, because of the.inherent value of
ecolojpcal systems and their strong links to human
17
-------
EPA Should Improve The Data And Analytical
Methodologies That Support The Assessment,
Comparison, And Reduction Of Different
Environmental Risks
E-4-0
H-6.0
S-4.7
The ability to assess environmental risks, compare
them, and select strategies to reduce them all depend
on the availability and sophistication of the relevant
data and analytical tools. The weakness in Unfinished
Business stems in large part from the weakness of the
data and analytical tools used, and those weaknesses
still exist. If &A's efforts to assess, compare, and
reduce risks are to improve in the future, the data
and analytical tools must improve as well.
For example, in order to generate the
exposure-dose data needed to assess human health
risKs more reliably, EPA should monitor chemicals in
the environment and in human tissues much more
systematically. Biomarkers and other
newly-developed measures of exposure should be
used. To this end, EPA should expand its research
and data collection efforts in this area, and cooperate
with other Federal agencies to facilitate development
of the reguisite data bases.
EPA's health-related data collection efforts should
not be limited to those areas where risks to
health already are recognized. EPA also needs to
develop an ability to predict the potential future risks
of emerging problems (e.g., low-level exposures to
electromagnetic fields). Therefore, EPA should
establish a formal risk-anticipation mechanism,
including an in-house expert committee, peer
oversight, and long-range research on emerging
problems.
Improved methodologies for comparing different
human health risks also are needed. A new approach
to ranking risks, one that uses a matrix of data on
sources, exposures, agents, and endpoints, is needed
to help identify specific agents and mixtures for
quantitative risk assessments. Risk rankings should
be based on risk assessments for specific toxic
agents, or definable mixtures of agents, and on the
total human exposure to such agents. When possible,
risks should be assigned to persons in target or more
sensitive populations, as well as to the population as
a whole.
For assessment of non-cancer human health risks,
the Agency should try to establish a risk assessment
framework consistent with that used for carcinogens.
Furthermore, although a large number of non-cancer
health endpoints exist, there is as yet no easy way to
combine assessments of cancer and non-caneer risks
into a single, overall health evaluation. The Agency
should explore procedures to achieve this end.
Improved data bases and methodologies for
assessing ecological and welfare risks also are
needed. For example, although ecological data are
plentiful, they have not been synthesized into
formats useful for assessing ecological risk.
Moreover, a substantial amount of ecological data are
collected and maintained by other Federal
government organizations/EPA should aggregate
ecological data that are collected government-wide,
and systematically synthesize those data into formats
useful for ecological risk assessment.
Finally, all three RRRSC Subcommittees took initial
steps in developing methodologies that would allow
a more rigorous, scientifically defensible comparison
and merging of environmental risks and alternative
strategies for reducing them. Those methodologies
are described in detail in the appendices to this
report EPA should invest in both in-house and
extramural research to help improve those
methodologies. Unfinished Business took the first steps
to compare environmental risk; the appendices to
this RRRSC report describe more sophisticated
approaches. EPA should ensure that these ideas are
developed and tested in the years ahead, so that
relative risk reduction can be used as an effective,
continually evolving tool in the development of
national environmental policy.
18
-------
EPA Should Reflect Risk-Based Priorities In Its
Strategic Planning Processes
¦ '< The Agency needs to build on and improve the lands
g a • ( of analyses carried out by the authors of Unfinished
j Business and by the members of the RRRSC in the
preparation of this report and its appendices.
Ongoing assessments of different environmental
risks and the policy options for reducing them
should be carried out within EPA, but the Agency
should consider soliciting the input of external
groups and individuals with expertise and interest in
this effort. The results of such analyses — the
identification of relatively high-risk environmental
problems and the most promising strategies for
reducing them — then need to be incorporated
explicitly into the Agency's strategic planning
processes.
Recognizing that scientific understanding and
public concerns are constantly evolving, EPA should
update its risk-based priorities periodically. A major
review of remaining and emerging environmental
risks facing the nation — and the globe — should be
conducted every several years in order to reflect
advances in scientific knowledge and process in
mitigating environmental problems over tune.
Specific strategies for reducing specific environmental
risks should be reviewed and updated more often.
Risk reduction strategies always should be driven
by the environmental problems to be solved, not by
the structure of existing government programs. Thus
it is useful to analyze problems from different
perspectives — for example, as pollutants (e.g., toxic
air pollutants, groundwater pollutants), as sources
(e.g., automobiles, powerplants), in terms of their
effects (e.g., increased respiratory diseases, habitat
destruction), and in terms of the economic activity
causing or affecting them (e.g., energy use,
transportation systems, residential and commercial
development). Looking at environmental problems
from different perspectives will suggest different
types of strategic solutions, and EPA should develoj
plans for specific risk reduction programs only after
undertaking this kind of comprehensive,.
multi-faceted analysis.
The Agency should subject individual strategy
options to disciplined analysis to determine how
much risk reduction each will achieve. Information
on cost, timing, degree of certainty of results, and
ancillary benefits or risks should be included in sud
analyses. The decision matrix developed bv the
Strategic Options Subcommittee of the RRf Z
represents one approach for evaluating alt* *tive
strategies against a set of defined criteria. / . r
promising risk reduction strategies have been
defined, they should be built into EPA's program
plans in a coordinated and explicit way.
Since State governments generally implement
national environmental protection poliaes at the lod
level, State agencies need to incorporate relative nsl
assessments into their strategic planning, too. EPA
should encourage and support state efforts to asses
relative risks and the various policy options avaiiabt
to reduce them, especially since local action is the
moat effective response to many environment-
EPA support should indude financial resourc
technical assistance, and information, and sud.
support should be focused on those problems and
geographical areas where particular risks are likely i
be reduced the most, and in the most cost-effective
ways.
19
-------
EPA Should Reflect Risk-Based Priorities In Its
Budget Process
S-4J
Historically, EPA's budgets have reflected the
resources necessary to establish and implement the
regulatory programs mandated by Congress, with
virtually no focus on relative risk and cost-effective
opportunities for reducing relative risks. Accordingly,
over time there has been little correlation between
the relative risk of a particular environmental
problem and the EPA budget resources dedicated to
reducing it.
Spending by EPA is not — and should not be —
the sole measure of society's response to a particular
environmental problem. In fact, other Federal
agencies, State and local governments, private
companies, and individual families will have to play
significant roles in reducine the risks posed by some
environmental problems. However, among those
environmental problems that clearly necessitate an
EPA response, the Agency should shift its budget
priorities toward those problems posing the greatest
risks.
Although this change in budget priorities is a
necessary component of future national
environmental policy, such a change need not wwr
overnight Small but consistent changes would
accomplish the same objectives, and such changes
should be made as die Agency's understanding of
relative risks improves. Moreover, changes in EPA's
budget priorities need not result in allocations exactly
proportional to risk and risk reduction coals, since
some risks can be reduced at relatively low cost.
The Agency should initiate a specific process for
incorporating relative risk considerations into its
budgetary deliberations. For example, at the
beginning of the budget evele the Administrator or
Deputy Administrator of £PA could provide clear
guidance to the program offices regarding relatively
high-risk problems that appear to be relatively
underfunded. A second review to ensure that
relatively high-risk problems are given higher budget
priority could be completed just before the budget is
sent to the Office of Management and Budget. But
whatever kind of process is instituted, it is critically
important that a specific EPA administrative process
relates budgetary allocations explicitly to risk.
Finally, the Agency should take the lead in
ensuring that overall national efforts to reduce risks
are driven by cost-effective risk reduction strategies.
As activities by organizations outside EPA — at the
Federal, State, and local levels — become
increasingly important to the nation's risk reduction
efforts, EPA should guide, inform, and help
coordinate those efforts. As the Federal agency with
the most up-to-date, comprehensive understanding
of relative environmental risks and the options
available for reducing them, EPA needs to play an
active role in helping target national efforts to reduce
environmental risks.
20
-------
EPA—And The Nation As A Whole—Should
Make Greater Use Of All The Tools Available
To Reduce Risk
SAA
The main tool that this nation has used to reduce
environmental risk has been government-mandated
end-of-pipe controls and remediation or clean-up
technologies. Such "command-and-control" methods
for reducing risk have been very effective in
controlling some kinds of pollution, especially from
large, centralized sources. However, to control the
risks posed by widely dispersed sources like
naturally-occurring radon and some consumer
products, and to control the risks that remain after
the imposition of end-of-pipe technologies,
command-and-control approaches may not be as
effective. Consequently, other kinds of risk reduction
tools that appear to have great promise must be used
more extensively.
The RRRSC examined a variety of such tools,
including research and development, conventional
regulations, enforcement, and international
cooperative activities. Two general tools that appear
to hold particular promise are market incentives and
the provision of information.
The forces of the marketplace can be a powerful
tool for changing individual and institutional
behavior and thus reducing some kinds of
environmental risks. Whenever appropriate and
feasible, EPA should use and/or support them.
Marketable permits, deposit-refund systems, and
pollution charges are types of market incentives that
could — and should — play much larger roles in this
nation's efforts to reduce environmental risk.
EPA is only one of several Federal agencies with
authority in these areas, but EPA is the Federal
agency primarily responsible for protecting the
environment in the broadest sense. Consequently,
EPA should take the lead in fostering more
widespread use of market forces to reduce
environmental risk.
Information also can serve as a way to reduce risk
without the use of command-and-control regulations.
For example, the information requirements of the
Emergency Planning and' Community Right-to-Know
Act or 1986 have encouraged companies to take
voluntary actions to reduce their inventories and
emissions of toxic substances. The exchange of
information also can facilitate the wider use of
cost-effective pollution prevention strategies. .
Information provided through environmental audits
can help companies improve their risk-reduction
efforts. EPA should expand its efforts to provide
information and to facilitate information-sharing that
helps individuals, businesses, and communities
reduce environmental risk.
This recommendation is not meant to imply that
command-and-control regulations have outlived theii
usefulness. For some environmental problems,
conventional regulatory approaches hold substantial
promise for further reductions in risk. Such
approaches include end-of-pipe performance
standards, design standards, use restrictions, and
product specifications. Together with strict
enforcement of existing environmental regulat
these approaches give pollution sources a stro.
incentive to look for cheaper, innovative ways to
achieve the same environmental goals. Thus' the
RRRSC supports the continued use and strict
enforcement of existing regulations.
However, die long-term reduction of
environmental risks will require EPA, and the natioi
as a whole, to use a far broader range of tools. EPA
should dedicate budget and personnel resources to
develop, test, and fairly evaluate all such tools. The
Agency also should make more of an effort to infori
and encourage other elements of society —
businesses, saiools. State and local governments,
etc.— to use this broad range of tools.
21
-------
7. EPA Should Emphasize Pollution Prevention As
The Preferred Option For Reducing Risk
S-4J
The costs of cleaning up and disposing of pollutants
after they have been generated can be enormous.
The costs of the Superfund program, the planned
cleanup of the Department of Energy's nuclear
weapons plants, and the cancellation and disposal of
chemicals already in use are painful examples of that
lesson.
Thus end-of-pipe controls and waste disposal
should be the last line of environmental defense, not
the front line. Preventing pollution at the source —
through the redesign of production processes, the
substitution of less toxic production materials, the
screening of new chemicals and technologies before
they are introduced into commerce, energy ana
water conservation, the development of
less'-polluting transportation systems and farming
practices, etc. — is usually a far cheaper, more
effective way to reduce environmental risk, especially
over the long term.
More widespread use of pollution prevention
techniques hinds enormous environmental and
economic promise for a number of reasons. For one
thing, some environmental problems — like global
wanning — simply cannot be remediated in any
practical way using only end-of-pipe controls.
Pollution prevention also minimizes environmental
problems that are caused through a variety of
exposures. For example, substituting a non-toxic for
a toxic agent reduces exposures to workers
producing and using the agent at the same time as it
reduces exposures through surface water,
groundwater, and the air.
Pollution prevention also is preferable to
end-of-pipe controls that often cause environmental
problems of their own. Air pollutants captured .in
industrial smokestacks and deposited in landfills can
contribute to groundwater pollution; stripping toxic
chemicals out of groundwater, and combusting solid
and hazardous wastes, can contribute to air
pollution. Pollution prevention techniques are
especially promising because they do not move
pollutants from, one environmental medium to
another, as is often the case with end-of-pipe
controls. Rather, the pollutants are not generated in
the first olace.
The advantages of pollution prevention also are
becoming apparent as the nation tries to address
some of the environmental risks that remain after
end-of-pipe controls are applied. Ongoing growthin
the amount of wastes generated in this country is
quickly overcoming the ability of landfills and
incinerators to absorb it, especially since landfills are
no longer an option for hazardous waste disposal.
Society must find more ways to reduce the amount
of waste requiring disposal. Similarly, as the nation
attempts to reduce the environmental risks still
posea by urban smog more than a decade after
automobile emissions were reduced sharply by
end-of-pipe technology, it is dear that preventing
pollution — e.g., through mass transit, car pools,
and the combustion of alternative fuels — is a
promising long-term option.
In addition, pollution prevention techniques often
bring substantial economic benefits to the sources
that use them. Businesses can avoid the costs of
end-of-pipe controls, waste cleanup and disposal,
and liability by preventing pollution instead of
controlling it. Moreover, some pollution prevention
techniques, like using energy more efficiently and
recycling process materials, can pay for themselves
quite apart from environmental considerations. One
reason that japan and Western Europe are
formidable economic competitors U that they use
energy and raw materials so efficiently. To compete
in the global marketplace, American businesses also
must use them more efficiently.
22
-------
8. EPA Should Increase Its Efforts To Integrate
Environmental Considerations Into Broader
Aspects Of Public Policy In As Fundamental A
Manner As Are Economic Concerns
S-U>;
For the past 20 years EPA has been the focal point of
the Federal government's environmental protection
efforts. As such, EPA was largelv responsible for
defining, implementing, and enforcing the national
command-and-control regulations that have been
remarkably successful in reducing certain kinds of
pollution, especially from large, centralized facilities.
But reducing environmental risk in the future also
will entail the control of small, widely dispersed
sources of pollution through the use of a wide range
of regulatory and non-regulatory techniques.
Consequently, EPA must have a broader perspective.
In solving environmental problems like habitat
destruction, indoor air pollution, non-point source
water pollution, and solid waste disposal, EPA will
be only one of a number of Federal and state
agencies with important roles to play. Thus EPA
should do more to foster the cooperation among
government entities that will be essential to the
national effort to reduce environmental risks in the
1990s and beyond.
EPA should play an important role in ensuring
that environmental considerations are a part of the
policy framework at other Federal agencies whose
activities affect environmental quality directly or
indirectly. Changing Federal policies in sectors not
traditionally linked with environmental protection
could provide cost-effective environmental benefits
that equal or exceed those that can be achieved
througn more traditional means.
Environmental considerations should be an integral
part of national policies that affect energy use,
agriculture, taxation, transportation, housing, and
foreign relations. For example:
• Energy conservation measures, if given high
national priority, could improve the U.S. balance of
payments; lower future world oil prices, reduce
threats to national security, and help reduce
environmental risks locally, regionally, and globally.
• Federal agricultural policies and programs could be
revised to reduce or eliminate existing incentives for
environmentally unsound fanning practices, and to
directly support efforts by farmers to control soil
erosion and chemical runoff and to make greater use
of low-input, sustainable farming practices.
• Tax policies could promote investments in new
plants and equipment that are less polluting and
more energy efficient.
• Housing and commercial development policies
could be used to control development in ecologically
fragile areas.
Because EPA is not the only Federal agency whose
actions affect the environment, it must work to
ensure that environmental considerations are
incorporated into policy discussions across the
Federal government. Environmental consider?
should be as fundamental in this context as e«.
concerns are. In order to facilitate the
government-wide integration of environmental
policy, the EPA Administrator should encourage the
President to create a cross-government forum where
such integration would be explicitly considered and
earned out
23
-------
EPA Should Work To Improve Public
Understanding Of Environmental Risks And Train
A Professional Workforce To Help Reduce Them
S-4.9
In a democracy the support of individual citizens is
important to the success of any national endeavor. In
the national effort to reduce environmental risk, such
understanding and support is essential, because both
the causes of and solutions to environmental
problems are often linked to individual and societal
choice. Consequently, EPA must expand its efforts to
educate the public in general and the professional
workforce in particular, both in terms of what causes
environmental risks and what reduces them.
For example, EPA should work to reduce the gap
between puolic perceptions of risk and the scientific
understanding of risk. In many cases, public
perception and scientific understanding are quite
different, if only because scientists have ready access
to information that the public does not. It is
important that EPA increase its efforts to share risk
information with the public, because in the long run
the public will have to approve EPA's risk-based
action agenda. Better public awareness of relative
environmental risks will help the nation allocate its
resources to maximize risk reduction.
At the same time the Agency must be attuned to
the concerns of people who are closest to the
real-world health, ecological, and welfare risks posed
by different environmental problems. An engaged
public often can be helpful m gathering information
that supports the technical analysis of nsk.
Moreover, because they experience those risks
first-hand, the public should have a substantial voice,
in establishing risk-reduction priorities.
Thus EPA should include broad public
participation in its efforts to rank environmental
£sks. Such participation will help educate the public
about the technical aspects of environmental risks,
and it will help educate the government about the
subjective values that the puolic attaches to such
risfcs. The result should be broader national support
for risk-reduction policies that necesarily must be
predicated on imperfect and evolving scientific
understanding and subjective public opinion.
EPA also should take several specific steps to
develop and sustain the nation's scientific capability
and workforce. For example, the Agency should
provide technical and financial assistance to
universities to help them incorporate environmental
subject matter into their curricula and to train the
next generation of environmental scientists and
engineers.
In this regard, EPA also should support graduate
and post-graduate training programs in the relevant
scientific disciplines, and nurture the participation of
the scientific community in interdisciplinary research.
The nation is facing a shortage of environmental
scientists and engineers needed to cope with
environmental problems today and in the future.
Moreover, professionals today need continuing
education and training to help them understand the
complex control technologies and pollution
prevention strategies needed to reduce
environmental risks more effectively.
. EPA also should expand its support for
environmental training programs targeted at Federal,
State, and local officials. Most environmental officials
have been trained in a subset of environmental
problems, such as air pollution, water pollution, or
waste disposal. But they have not been trained to
assess and respond to environmental problems in an
integrated ana comprehensive way. Moreover, few
have been taught to anticipate ana prevent pollution
from occurring or to utilize risk reduction tools
beyond command-and-controi regulations. This
narrow focus is not very effective in the face of the
intermedia environmental problems that have
emerged over the past two decades and that are
projected for the future.
24
-------
EPA Should Develop Improved Methods To
Value Natural Resources And To Account For
Long-Term Environmental Effects In Its
Economic Analyses
E-&2
1
Traditional forms of economic analysis, as applied to
the costs and benefits of economic development and
JUIC *VW MW W»»1IW w*
environmental protection, have systematically
undervalued natural resources. This practice
threatens the world's natural resources — like
estuaries and rainforests — without which the lives
of future generations will be impoverished. The
failure of current analytic techniques to estimate
properly either the full benefits of natural ecosystems
or die full costs of activities that degrade them too
often has allowed the justification of long-term
ecological degradation for the sake of present gain.
A private company invests its profits to maintain
and increase its capital value. When a company
invests to maintain facilities, expand production, buy
new equipment, and improve me quality of services
provided, it protects its long-term health.
In a similar manner, this planet reouires certain
investments in order to maintain itself as a healthy
ecosystem and to ensure sustainable, long-term
economic growth. Future generations depend on
those investments, and if they are not made, then
civilization will put itself out of business.
It is necessary and appropriate to conduct
economic analyses of human activities that affect the
environment. But it is essential that such analyses
properly value the long-term, sustained productivity
of natural ecosystems, for that reason, EPA should
undertake a broad national effort to develop
analytical techniques that more adequately assess the
real long-term value of ecosystems, and mat support
the identification of the most cost-effective ways to
reduce risks that threaten long-term, sustained
productivity.
There are a variety of problems with present
methods. Many of the problems stem from the fact
that public .goods, such as clean air, are unpriced in
markets and thus are easily — and often—
undervalued in economic analyses. National
accounting schemes typically characterize revenues
generated by activities that deplete or degrade
environmental resources as "income" while failing to
consider the resulting depletion of society's
environmental capital assets.
When economists do try to value ecosystems, they
are hobbled by the limitations of the available tools.
For instance, the "willingness to pay" method can
significantly undervalue aspects of ecosystems with
which people are not familiar. Some of the
assumptions underlying discounting procedures do
not hold when environmental effects occur over long
time periods; thus they assign little value to some
very important long-term effects. Multipliers that are
applied differently to environmental values than they
are to mote traditionally measured economic values
(e.g., employment) may further distort the results of
economic analyses.
As a first step EPA should commission a stu'
that surveys the ideas of ecologists, economist
social scientists, and other experts from inside a»_
outside the Agency. The study should attempt to
develop a way of incorporating ecological
investments into a concept of sustainable growth.
Environmental economics is a controversial,
complex, and rapidly-evolving field. EPA should taW
the lead in developing methods of analysis that will
give fair consideration to investments that will
protect the natural resource base for future
generations.
25
-------
This overview report has been derived mainly
from three detailed reports prepared by the
three Subcommittee!, of the Relative Risk
Reduction Strategies Committee. Those
reports are:
• Appendix A: Report of the Ecology and Welfare
Su6ammittee(EPA-SAB-kC-90-Q21A).
Includes a critique of the ecological and
welfare rankings in Unfinished Business.
Suggests an alternative approach to defining
environmental problems, ranking them from
an ecological perspective. Identifies a need to
more accurately reflect ecological concerns in
economic/welfare considerations.
• Appendix B: Report of the Human Health
Suixommtlee(EPA-SAB-EC-90-€21B).
Includes a critique of the cancer and
norxancer rankings in Unfinished Business.
Provides specific suggestions for
methodological improvements for analyzing
and evaluating relative risks of environmental
problem, including a possible approach for
merging cancer and non-cancer concerns.
• Appendix G Report of the Strategic Options
SalmBjmttee(EPA-SAB-EC-9W321Q.
Describes the wide range of "tools"
available for addressing environmental
problems. Includes 60 examples of such
strategic options applied to 13 different
environmental problems. Provides a set of
criteria for selecting from among the options
in any given case.
Copies of the three appendices to this
report can be obtained by writing:
The Science Advisory Board (A-101)
U. S. Environmental Protection Agency
401M Street, S. W.
Washington, D. C 20460
26
-------
'11111'III 111111 III' I" " I' I'11'"!" I"v? t' ?!'" " I ''I'll 'l'l 'l'I'll *?'!'Tl I II I? 'I I'I I 'II'" I""" I" 11I'I 'I IIIII111*1 11"|"" •'.•'.•y •'.*!• "•/'•yyl''']'!yT'vyy' ''.i")'1'1|-uXy •'•'i'i'i: ' i if-i-i-nni Hi• i iii j j; j i i i j - rj j j i j 1 ivi:i i i j
from
¦ • ' ' ' ' ' ¦ • ' ' ¦ ' - - ¦ : ¦
oikos - house, place to live
study of the relation of organisms or
groups of organisms to their
environment
study of the function and structure of
nature
-------
ECOSYSTEM
An area
to produce
D
ofTftnng organisms and non-living substances interacting
an exchange of materials between living and nonliving
Naturally occurring ass
;mbl^gj^ of sipecies living ih and interacting
with the same environment; thes/species are mutuaDV
sustaining and interaCSendent. rs^
-------
STRUCTURE OF NATURE
-------
FUNCTIONS OF NATURE
Capture aitftronversion of energy
~u
Cycle water and carbon
-------
second carnivore
first carnivore
herbivore
plant
decomposers
. -'.kit - -
—» . >,
JTr' M*. *- -V
"t: *r-V^S- *
" ; J..3 -
-------
T^.m\
' ' ".'rujj
a«^ -: :
•• •••¦<-. ¦;.'
s?:v;<
«|i:
r»j l|H 8£s#$
-------
Carbon Cycle
An acre of typical farm
soil contains
1 ton fungi
several tons of bacteria
200 lbs of protozoa
100 lbs of algae '
100 lbs of yeast
-------
i
-------
s^At I * ^
nu"^Ns T
Wetlands Cafe
MENU
The food chain begins when leaves, iwigs, and
dead branches fall lo ihe ground in the wetlands.
Here bacteria, worms, and insects break down
the vegetation into a rich organic broth called
detritus. Nutrients and minerals are released
and fciiilizc the wetland plants. Crayfish,
birds, snakes, turtles, mammals, fish, and
linally people, all play an important
part in the life-sustaining
lood cycle in a wetland.
"...
I%
¦•"¦I I (
-------
WHEN WE TRY TO PICK OUT ANYTHING BY ITSELF, WE FIND IT HITCHED TO EVERYTHING
ELSE IN THE UNIVERSE.
JOHN MUIR
-------
WHY FORESTS NEED SQUIRRELS
Until recently, the interdependency of plant and animal
species was largely ignored by foresters, who endorsed clear
cutting vast tracts of forest land as the only way to manage
our timber resources. In doing so, of course, forest
companies alter complex forest ecosystems forever by
wiping out all tree species and habitats. In his 1990 book,
The Redesigned Forest, author and biologist Chris Maser
demonstrated the close connection between the forest and its
inhabitants in a description of the northern flying squirrel.
A native of the Pacific Northwest, the squirrel feeds on a
certain fungus found in the forest floor. The fungus is
digested by the squirrel and excreted in the form of
droppings of "pellets."
Each pellet, says Maser, is like a "symbiotic pill." It
contains four components of great value to the forest:
spores of the fungi, yeast, nitro-fixing bacteria, and the
complete nutrient component for the nitrogen-fixing bacteria.
Whenever the pellets fall on the ground, they create fertile
conditions. More of the valuable fungi are propagated and
the overall fertility of the forest is increased. In a clear cut
area, the squirrel disappears; without the squirrel, soil
fertility is decreased. The northern flying squirrel illustrates
only one of thousands of such relationships in any given
forest.
-------
WHAT CAN GO WRONG?
loss o
loss o
Simplif!catkm>pf biologic communities
cies
¦ redundancy (extra pieces)
u
Overwhelm a cycle by injecting pollutants
Alter or remove physical environment
Food web collapse du
RCy species
-------
SO WHAT?
3
If the landGmchanism as a whole is good, then every pqitQ is good,
whether wc understand it or not. If the biota in the co
iry pomt is gc
e course}
"cfieohs has built something we like but do not und 'rstand,
thmwho but a fool would discard seemingly usel&s parts?
To keep every cog and wheel is the first precawjg^ of
intelligent tinkering.
c
u
o
n
V^Aldo Leopold^/
u u
-------
SO WHAT?
u
Loss of Ecosystem values
Life support
Economic
Scientific
Genetic diversity
Recreation
Historical
Aesthetic
rieiigiJusj
^4Jharact€r ^taiJding
u
-------
Values of Ecosystems
Why do we want to protect ecosystems? Do we really need functioning ecosystems?
The obvious answer to that question is yes since we all live in (or live off of) an ecosystem.
Understanding the values of ecosystems is the starting point for ecosystem protection.
Without values, protection is not needed. Do humans really need to value an ecosystem to
justify the protection? Human definitely use portions of ecosystems. This is generally how
we value our natural resources. "Added value" is when labor is put into a process to provide
a more refined product. Every living thing exploits the environment for its biological needs.
They also must endure the hardships caused by the environment, especially the hardships
caused by alterations of the environment by one of its inhabitants. Humans have also
developed beyond the capability to value an ecosystem for merely its biological uses.
Humans have the power to understand, appreciate, and enjoy the environment far beyond
their biological uses of it. Humans enjoy scenic vistas, scientific studies of nature, and the
challenges the environment offers. Nature is endlessly stimulating to the mind and bores
only the ignorant and insensitive.
Not all human enjoy all the values of nature. The function of ecosystems provide
many values. When ecosystems cease to provide functions, what is valued is lost.
1. Life-Support Value
Human depend on airflow, water cycles, sunshine, photosynthesis, nitrogen fixation,
decomposition bacteria, fungi, the ozone layer, food chains, insect pollination, soils,
earthworms, climates, oceans, and genetic materials. Human life would not be possible
without these, and many more, ecosystem attributes and processes. The necessities of life
are provided by specific ecosystems. Human evolved out of ecosystems, and therefore rely
on ecosystems for their sustainability. If ecosystems cease functioning, so does their ability
to provide us our life-support needs.
Humans could not have survived (nor evolved) in an extremely harsh environment.
Same as to say about benign environments, human evolution would have stagnated. All our
cultures exist because of oppositional nature, portions of ecosystems which are harsh to
human survival. An ecosystem always lies in the background of all cultures. Humans will
always remain in and rely on ecosystems no matter how hard we try to distance ourselves
from nature.
2. Economic Value
Every living thing, being part of an ecosystem, makes portions of that same
ecosystem into a resource. Achieving economic value requires manipulating a natural thing
coupled with commerce. All our goods are made out of pieces from nature, composed
together to serve a function. Adding-on of labor to a natural thing adds value to something
originally thought as economically valueless by humans. Economies are built around the
commerce of natural resources. Renewable natural resources, being a part of an ecosystem
can sustain economies. There will always be an ongoing search in the environment for new'
discoveries on which we can build our economies. When the ecosystem is stressed to the
point where it can no longer sustain its self, neither can the economy.
3. Scientific Value
-------
Natural science is our most sophisticated cultural achievement. Valuing science is an
intellectual adventure. Science focuses on primitive nature and the less understood aspects of
ecosystems. Diversity in an ecosystem is the raw material for science. One recent example
are the thermal pools in Yellowstone. Recent scientific studies suggest that the anaerobic
bacteria in these pools have changed very little since when life evolved in an oxygen-free
atmosphere. Humans will always pursue science to help build our cultures and improve our
well being.
4. Genetic-Diversity Value
Humans depend on genetic diversity, although it may not appear so. With the loss of
fifteen cultivated plants, one-half of the world would starve. Ten species provide 80 percent
of the world's calories. Genetic diversity gives us the ability to develop varieties of crops to
sustain the world's population. Decreasing the ecosystem's ability to function will decrease
the available genetic diversity. Genetic diversity may hold the key to the sustainability of the
human species. A decrease in the genetic diversity will also decrease many of the other
values humans have of ecosystems. Genetic richness is contained in all organisms within an
ecosystem.
5. Recreational Value
People like to recreate in the environment because they are surrounded by something
greater than anything they find indoors. Examples are fishing, hiking, running, rafting,
photography, skiing, only to name the most obvious. The need recreate in the environment
is part of human sentience. Without sentience, we would have no curiosity or desires for
achievement. Food, water, and shelter would be all that is required for our existence. With
sentience, humans want a lifestyle with zest; not a boring and lifeless, yet sustainable
lifestyle. In some forms of recreation, people enjoy watching wildlife and landscapes in
places where a rich evolutionary ecosystem is still in existence. For example, an amateur
botanists will enjoy the exertion of a hike up a peak while he/she observes the alpine plant
communities. Altering an ecosystem may also alter recreational experiences in the
environment.
6. Historical Value
Undisturbed ecosystems provide historical value in two ways, cultural and natural.
Every culture exists within an ecosystem. Direct link between historical cultures and the
environment. No culture develops in independence of the superimposed environment. To
understand our historical cultures, we must also understand the ecosystems in which they
reside. When Europeans came to North America their culture was developed based on the
ecosystems in which they carved out their existence. Symbolically, cultures identify with
nature. The Columbine flower is Colorado's state flower, the Bighorn Ram is the state
animal. Canada's symbol is the maple leaf, England's is the lion, and the United States' is
the bald eagle. Preserving culture also means preserving the environment from which it was
carved. Preserving natural areas will allow us to express our culture values.
Naturally, ecosystems provide a historical museum the way the world was throughout
the world's evolutionary period. Losing pieces of ecosystems, will hide secrets to history.
Each ecosystem is historic because no two are alike.
-------
7. Aesthetic Value
Human experiences are enriched by beauty and art. Humans value nature in its purist
form for its natural art and beauty. Intact ecosystems contain beautiiul and artistic creations
If ecosystems are altered, so is the beauty and artistry.
8. Character Building
Nature is used to as a place to go to evaluate one's character. It is place to address
personal insecurities and learn how to step beyond the recognizable. It is a place to push
one's self beyond their comfort zones and to broaden the understanding of one's internal self
Learning to sustain one's self within the environment can be applied to many situations
throughout one's lifetime.
9. Religious Value
Nature is a religious resource or sanctuary. People feel as if something "Greater
exists in the wilds. For some, its a place to pray or meditate. People sense a spirituality of
place. When the natural place is altered, so is the religious experience.
. . .... snme 0f these values of ecosystems. If ecosystems are
* ^ ^ CarT ~ thp function or sustainability of the system declines, the quality
altered to the point to where fl.e ^ cuItoreS! ^ the
of the environment's economic goods, the quality ui uiu j
quality of our experiences in the environment w
-------
BIOLOGICAL DIVERSITY
(Biodiversity)
The variety and variability among living organisms and the ecological complexes in which they occur
Office of Technology Assessment
At the ecosystem level:
The mosaic of habitats and communities of living organisms within an area.
At the species level:
The number of different plants and animals which is of concern of the Endangered Species Act.
At the genetics level:
The variation in the gene pool for a population of organisms.
-------
BIODIVERSITY
The one process now going on that will take millions
of years to correct is the loss of geneitc and species
diversity by the destruction of natural habitats.
Aldo Leopold
The Ecological Conscience, 1947
Every country has three forms of wealth: material,
cultural and biological. The first two we understand
well because they are the substance of everyday lives.
The essence of the biodiversty porblem is that
biological wealth is taken much less seriously. This
is a major strategi error, one that will increasingly be
regretted as time passes.
Edward O. Wilson
The Diversity of Life
-------
SO WHAT?
-------
SO WHAT?
Pollution Overwhelms Nutrient Cycles
Too much phosphorus and nitrogen from runoff and erjrisftxn caused
of Lake Erie and the severe decline of
inAgis)Hes in Chesapeake Bay.
Too much phosphorus leads to "ffl
recreational areas and c|in eirsouragel production o
-------
SO WHAT?
Toxics Eliminate Key Species and Degrade Systems
DDT applicj
to explode.
in Borneo caused plague carrying rat populations
n
Soi^ec^systems are sterilized by salts, pesticides ani fertilizers ir
cotton producing areas. Soil productivity is lost^ "
becomes toxic.
soil even
Oil spill in Prince Willia
populations which are key sp
Acid rain eliminates forepts and meir cycling process and ability to
provide products andj^Jues. roreptjl)ss increases tpiLloss
through erosion.
n
n
drastically r
to peopl
Hy rcducrd
tkainl man'
salmon
many other animals.
-------
A System Gone Awry
WATERSHED
PROTECTION
• An Integrated, Holistic Approach *
-------
Figure 3.19 Borneo rat patrol.
(
!
-------
The Borneo Rat Patrol
At one time, malaria was a major health problem on the island of
Borneo in Indonesia. To help the people of Borneo, workers from
the World Health Organization sprayed remote villages and nearbv
areas with DDT. Most of the mosquitoes in the sprayed area were
wiped out, but because other organisms are contort-
other through the food web, other organisms also were affected.
Flies and cockroaches, the favorite food of lizards that lived in
the remote villages, died from the DDT. The lizards qoraed
themselves on the DDT-poisoned insects, and they, too beoan to
die. Local cats ate the infected lizards and died After the
cats died, the rat population grew unchecked.
The malaria-carrying mosquitoes were killed by the DDT but th<*
rats in the village carried plague that was transmitted to
humans. Although the people on the island no longer had to worrv
about malaria, they began to died from plague. To restore the
balance in the tropical ecosystem, cats were parachuted into th*
remote villages so thy could eat the rats. This is another
example of the unplanned effects that humans have on other
organisms and themselves, because of the interaction of mam,
organisms in a ecosystem. *
-------
SO WHAT?
Loss or Alteration of the Physical Environment
Loss of wetkuni, riparian, and floodplain sponges lead to
enormous Economic losses due to floods.
jj:
Baitifers, changes in flow patterns, and elimination of habitat due
to land uses destroyed the salmon industry of t^ePacific Northwest.
n
looi is11 of algae tl lat ruin
nJ
Too much phosphoruslaads
recreational areas ai(d^an encoui^ige' production ofto^ic algae.
u u
-------
40A ~~~
Houston Chronicle
Sunday, Nov. 27,1994
Flood
Continued from Page 37A.
shift in flood control is needed. In-
stead of erecting more dams and
levees, tbe committee believes tbe
goal should be removing people from
the flood plain and giving it back to
Mother Nature.
However, that would require mil-
lions — probably billions — of dol-
lars.
Although final tallies have not yet
been made, in Southeast Texas sev-
eral thousand families such as tbe
Philiipses will be denied permits to
rebuild unless they elevate their
homes — sometimes more than a
dozen feet Flood regulations stipu-
¦ late that any home in the flood plain
¦ that is more than SO percent dam-
aged cannot be rebuilt unless raised
• a foot above the 100-year flood plain.
Those denied permits, mostly from
the hardest hit areas in Harris, Mont-.
gomery and Liberty counties, could
qualify for federal buyout programs.
However, funding is only available
for "a few hundred," said Wade
Nofager. the state's hazard mitiga-
tion officer, who is charged with
compiling a prioritized list of poten-
tial buyouts.
Homeowners wanting to be relo-
cate! agonize that they may not
make the cut and then won't have
sufficient insurance or savings to
nise their existing homes.
Other homemakers say they're not
budging from their scenic water-
front settings and are irate that
government restrictions could make
it impossible to restore their prop-
erty.
SttO others are ignoring rales and
moving forward with repairs—even
though regulators warn that such
. improvements can be "red-tagged"
and ordered torn down.
County, state and federal authori-
ties say the flood control problem
runs much deeper than this year's
record flood;
¦ From 1989 to 1993, there were
¦ five times more presidential disaster
declarations for floods in the United
States than any other disaster, a
federal study found. Liberty County,
: for instance, laid claim to five of the
112 declarations during those five
years as the result of the Trinity
: River* forays from its banks.
a In the last 10 years, the average
cost of flood damage in the United
Stats has surged from $2 billion to
P billion a year, the same study
showed, The Federal Emergency
Management Agency is also report-
ing spending ;200 million each year
for flood recovery.
"Many of the nation's levees were
built Airing the Depression, as pub-
lic works projects," said US. Sen.
Max Baucus. D-Mont, chairman of
the Environment and Public Works
- committee. "No one realized that the
to move into harm's way. I^Tone
knew that the wetlands being filled
in were natural sponges that help
ease Hood losses. No one knew how
irr.nmtiinr wrest inn would herome
I to oar economy and how much it developments 10 times (aster than 10
) would depend on healthy rivers." ^ years ago. I've watched the situation
/ J^vironrawtalists note the flood] get worse with every development
^"""^rtainsalsoprwide rich soil for land flood control project."
Sawiearine Wdwood forests that / Christiansen's home in Highlands
^rebranches and leaves to the was inundated with seven feet of
river The branches and leaves then J water last month - nearly twice as
decay and become part of tbe food / much as when it flooded
chain that ultimately feeds the fish.
"We have straitjacketed our riv-
ers, increasing flood heights and
creating a false sense of security
that has actually , encouraged the
development of flood-prone areas,"
stated a letter signed by officials of
eight environmental groups includ-
ing the Sierra Club, National Wildlife
Federation and National Audubon
Society. —
These groups, like Clinton's review
committee, recommend adopting
"watershed management plans" for
each river system.
Watershed councils could develop
strategies for stowing runoff by cre-
ating retention poods, planting vege-
tation, establishing wetland pre-
serves and barring further develop-
ment in flood plains.
"People need to come together and
see how water is moving and im-
pacts development in other areas,
not work independently," said Scott
Faber of Washington D.C, spokes-
man for American Rivers, a conser-
vation group.
He contends flooding is worse in
the San Jacinto and Trinity water-
sheds because of an increase in
development, not rain.
Texas as a whole is among the
worst violators for. having no signifi-
cant flood policies," said Faber.
James Kowis of Austin, flood plain
manager for the Texas Natural Re-
source Conservation Commission,
said he is forced to agree.
"Today, there is no flood-plain
management from the state. We only
have $130,000 from a federal grant to
work on flood plains. Tbe state has
no comprehensive plan," Kowis ad-
mitted. "We just assist local govern-
ments as much as we can. We have,
no real power at the state level to
work on Texas' 23 river basins where
there is significant flooding."
As the years pass, those living in
the bottom lands of the San Jacinto
and Trinity Rivers are noticing more
frequent and furious floods.
"I don't know what's causing it, but
before 1989 it very seldom ever
flooded out here; Since then that's
about all it's done. There are 10
recorded floods in the last five
years." said Charles Follis. a former
mayor of Dayton Lakes on the Trin-
ity.
He has been ready to throw in his
mop and accept a buyout since bis
community was only reachable by
boat for three months in 1990.
Brad Christiansen, a founding
member of tbe San Jacinto River
Association who has lived on that
river since his birth 37 years ago,
believes flooding there is worsening,
too.
"Twenty years ago. last month's
flood would not have happened with
__ during
Hurricanes Alicia and Carta.
Still, he's among those opposed to a >
buyout: "I made my choice~yearsT
ago. A little flood is not going to do
anything. 1 have flood insurance."
Texas is a major player in the
federal flood insurance program,
said FEMA's regional hazard miti-
gation officer Wayne Fairley in
Houston.
Residents of Texas, Louisiana and
Florida buy more flood insurance
policies and make more claims than
all the other states combined, he
said.
Describing a sort of cowboy men-
tality against land-use regulation in
Texas, he said. "Some see flooding as
a way of ltfe.1 have to understand —
until they put their hand to the
taxpayer and say 'Pay me for this.'
"It's not fair for the taxpayer to do
this over and over again. We need to
break the cycie."
A reform bill, sponsored by Baucus
and based on the review committee's
recommendations, was aimed at* j
breaking the cycle.
It would have eliminated govern-
ment incentives for new building in
the flood plain, authorized millions
more for buyouts in areas that re-
peatedly flood, required the U.S.
Army Corps of Engineers to invest in
"non-structural" alternatives and
called for watershed planning.
Yet the bill failed to win approval
before congress adjourned last
month.
However, it is expected to be
reintroduced next session, because
Baucus refused to let his bill go down
alone by linking its passage to the
Water Resources and Development
Act For the first time in a decade,
the development act which had been
routinely passed every two years to
fund levees and water projects was
also blocked — pushing Baucus'
point that new construction should
be contingent on reform.
"It was the most substantial thing
done for tbe environment in years,"
said Faber with American Rivers.
However, U.S. Corps of Engineers
spokesman Harry Shoudy is skepti-
cal reform will ever happen.
"Moving people out of the n«rl
plain is more difficult in practice
because in many cases people don't
want it. and it's far more expensive
than other alternatives such as a
levee or channel improvement," he
said.
But like many others who lost
nearly all they owned to MnHy,r
Nature, the Phillips family thinks
the only have one alternative; a buy-
out.
"It would cost twice as much as we
got from our flood insurance
elevate this house," said Lori Phii
lips, worried her family has iwL"
this rain." he said. "That runoff into a strange sort of bomTi
would have taken more than a week limbo. "We can't afford to iust r?
M crtt h*r» rtanrf nrnwit awav and Iaavd ' Wfllk
we
to get here. Flood control projects
are movine water from unstrcam
away and leave our home but
ran t e<> on like this forever "
-------
A lonely sockeye: They're the cultural icons of a region, but their sex drive proved no match for the huge hydroelectric dams
Bed Than Dead
Environment: The salmon of the Pacific Northwest are vanishing, but those
j ^ Akska are thriving. How much is it worth to save the southern stocks?
fN this ecology-saturated ace. Ev-
eryone can identify an endangered
species at 20 paces: lone elephants on
the Kenya plains, pandas so rare that
zoo loans from China required high-
'evel diplomacy. California condors that
must be raised bv human hand before they
can soar free. What an endangered species
does not look like, surely, is the contents of
a SI. 79 caj, 0f salmon. As Helen Cheno-
weth. a newly elected member of Congress
from Idaho, said at the Second Annual En-
dangered Salmon Bake in Stanley last sum-
mer- "How can I [take salmon's endan-
gered-species status seriously] when you
can buy a can in Albertson's?"
Representative-elect Chenoweth mav
lave to try harder. Alter decades of essen-
v no effective action to stop the salmon
Population oi" the Pacific Northwest from
P ungmg to 15 million from 100 million in
the 1850s, a reckoning day is coming. Un-
der court order, a four-state council will
vote next week on a new plan to save the
salmon of the Columbia River Basin. The
scope of the problem is not in dispute. Ac-
cording to one estimate. 107 separate salm-
on stocks—populations that were born in.
and hence return to spawn in. a particular
stream—are extinct: an additional 89 are
close to following them into history. Outgo-
ing Idaho Gov. Cecil Andrus keeps in his
otfice a mounted sockeye called Lonesome
Larry, the last one that made it back to
Idaho's Snake River, in 1992.
But Pacific salmon as a whole are no-
where near doomed, mostly because of fish
tanning and huge populations in Alaska.
"We've had record runs three of the last
five years there." reports Dennis Phelan of
the Pacific Seafood Processors Association.
"We're up to our eyeballs in salmon." How
much trouble and expense is justified to
save the Columbia River salmon, then, if
their Alaskan cousins are maintaining the
species quite nicely, thank you?
Romantic lore: From a legal standpoint,
the answer doesn't matter. The Endan-
gered Species Act requires that, when a
species is in danger of extinction, the feder-
al government implement a "recovery
plan." That can include restrictions on land
and water use. But politically, the answer
matters a lot. since any annoyed interest
group can appeal to the courts and tie up
recovery efforts for years. Salmon advo-
cates make their case on both romantic and
economic grounds. They cite the lore of the
salmon, and the pivotal role it plays in the
culture of the region, likening it to the bison
or the bald eagle. "The salmon is the heart
and soul of the Pacific Northwest." says
William Stelle of the National Marine Fish-
DECF.MBER1S.1994 NEWSWEEK 79
-------
-JPJ •UhW.rf'K .•»">*»& >»-.
streams
eries Service. Longtime fish activist Ed
Chaney says the salmon losses cost the
region's fishing and canning industries
S10 billion; losses of tourist and sporting
revenues push the cost higher.
Four key industries have combined to
cripple the Northwest salmon:
¦ Hatcheries breed and release geneti-
cally inferior fish. "You turn them loose and
they go belly up," says Chaney. Worse, by
interbreeding with wild stocks, they weak-
en those populations, too.
¦ Fishing reached such unsustainable
levels in the 1980s that this year, in an un-
precedented move, salmon catches off
Washington were banned.
¦ Logging can turn spawning
from nurseries into salmon-egg
poachers. With no shade, the
fragile eggs become too warm
to survive.
¦ The culprits most responsi-
ble for the Columbia-basin
salmon losses, according to fed-
eral. state and tribal wildlife
agencies, are the IS huge dams
that provide the region with
federally subsidized hydro-
power. The Grand Coulee
Dam. built in 1941. blocked
1.100 miles of salmon-spawning
grounds: Hells Canyon, in 196T,
blocked upstream migration on
the Snake River (map). Even
when adults bypass the dams by way offish
ladders, the behemoths may doom the off-
spring of those migrants. Slack water be-
hind the dams make migrating smolt vul-
nerable to predators, and turbines at the
dams puree many of them. Up to 95 percent
of some runs never make it to the ocean.
The Snake River's sockeye were designated
endangered in 1991. and its chinook runs
were listed as endangered this year. Coho
on the Snake went extinct in 1985.
In September a federal appeals court in
San Francisco ruled that the hydropower
system has to get serious about saving salm-
on. The ruling, in response to a suit filed by
activist Chaney, has put more pressure on
the Northwest Power Planning Council to
come up with a strategy at its December
meeting. (The council, which can set Ham
policy and is made up of representatives
from Idaho. Montana. Washington and Or-
egon. has failed to come up with a success-
ful salmon-friendly plan since federal law
mandated one in 1980.) Andrus wants the
council to order the lowering of the reser-
voirs behind four dams on the lower Snake
for 10 weeks during the spring run. That
would speed up the flows, sending the juve-
niles over the spillways rather than through
the salmon-mousse-making turbines.
But the council vote is expected to be
close. Utilities are lobbying for a forced-
busing scheme rather than 10 weeks of low-
Following the Fish
Once salmon were the kings of the
Columbia River. Today they're struggling
to survive amid the dams and forestrv.
IZJ Accessible to salmon
;—J Historically inaccessible
[3 Access now blocked
- Dam
BRITISH COLUMBIA
-» -yfuicouvrr -f\
Pacii
Ocean
ifor.
•WW-V»V I -5 VSV I. _¦ V ( v
iMJnuid ¦: VA
Seattle. ^ %V.Spotam-
Chinook Returns
to Snake River
.. qn
! ADULT SALMON
-J LSTEW11I9__„I.
ISNAKEIUVUL
PALL MUNI i I
—rTWTraoucon*) 20
•<> <7 ~
WASHINGTON >
• 82* 70 75 80 85 1994
"1961-65 AM BntUTD.
JOU*CE IDAHO DEFT, or
nlH AND CAME
. i
Chinook Salmon
Returns to Lower
Granite 0am
80
SOUBCC IDAHO DOT. Of
m AND GAMS
CALIFORNIA
NEVADA
-.T.irrwSI l-~3r ' r'
UTAH "V. 1 • WTO. I
i i -
NATALIE B. FOBES
Overkill: Spearing a Columbia salmon
er power production. Marine workers
would collect all the juvenile fish from the
Snake, then truck or barge them down to
the estuaries for release. That would be fine
with farmers, who depend on the water for
irrigation during the summer months and
don't want to see it "wasted" on preserving
the salmon. Trouble is. the Army Corps of
Engineers has been barging and trucking
smolt for 17 years, and the populations have
still been plunging. "You can't just FedEx
wild animals to the ocean and expect them
to survive." says Chaney. The aluminum
industry uses 20 percent of the dams' power
output, and it. too. opposes a drawdown.
Thanks to dam subsidies, the Northwest
pays the lowest electricity prices in thi*
country—40 percent below the national av-
erage—and farmers pay one thirtieth the.
going rate for water. f
Industry advocates want to protect those
rates. GOP Sens. Slade Gorton of Washing-
ton and Bob Packwood of Oregon have long
made noises about gutting the Endangered
Species Act. The costs of saving the North-
west salmon could spur them on. "Salmon is
going to endanger the Endangered Species
Act." boasts Chuck Cushman of the proper-
ty-rights group American Land Rights Asso-
ciation. "To paraphrase Lincoln. 'You can't
screw all the people all the time'."
But there are already victims of the policy
that favored dams over fish, particularly the
lucrative commercial- and sport-fishing in-
dustries. And "victims" of endangered-spe-
cies protection don't always materialize: de-
spite warnings that saving the spotted owl
would cost 120,000 jobs, the region has add-
ed 279,000 since 1991, thanks to firms at-
tracted by the Northwest's environment. If
salmon disappear from the Columbia, the
dams are going to make a sorry substitute as
the inspiring symbol of the region.
Sharon Becley with
Patricia Kinc in San Francisco and
Mary Hacer in WasAingron. D.C.
\
80
NEWSWEEK DECEMBER 12, 1994
-------
SO WHAT?
Exotic Spe :ies Destroy Food Webs
Invasion of zebra mussels is causing billions of dollars iiTcfamage
-to-structwes and is eliminating the basis of food wpbsfAero-is--)
noVkwwn remedy and they are spreading.
c
Mysid "shrimp" altered Vitie fboctfTHSC
caused kokanee salmon Jo die^oK and
Glacier National Paid* ^
tir
eagles to lea1 e
;akeCl^cii
D
U U
-------
-------
ECOSYSTEM MANAGEMENT PRINCIPLES
Broad spatial and temporal scales
Partnerships
Integrated, holistic i
Socially defined goals and management objectives
Adaptable institutions
-------
ECOSYSTEM MANAGMENT DEFINITIONS
National Park Service
Ecosystem management is a collaborative approach to
natural and cultural resource management that integrates
scientific knowledge of ecological relationships with resource
stewardship practices for the goal of sustainable ecological,
cultural, and socioeconomic systems.
Bureau of Land Management
Ecosystem management is the integration of ecological,
economic, and social principles. to manage biological and
physical systems in a manner that safeguards the long-term
ecological sustainability, natural diversity, and productivity of
the landscape. The primary goal of ecosystem management is
to conserve, restore, and maintain the ecological integrity,
productivity, and biological diversity of public lands.
Colorado State Office - Bureau of Land Management
Ecosystem management is fundamentally a process of
people and science working together to achieve landscape
health to sustain human well-being.
U.S. Forest Service
Ecosystem management means using an ecological
approach to achieve the multiple-use management of National
Forests and Grasslands by blending the needs of people and
environmental values in such a way that National Forests and
Grasslands represent diverse, healthy, productive, and
sustainable ecosystems.
Keystone National Ecosystem Management Forum
(referenced bv EPA)
Ecosystem management is an approach to environmental
management that is: 1) at a scale that is compatible with
natural systems, 2) cognizant of nature's timeframes, 3)
recognizes social and economic viability within functioning
ecosystems, 3) and is implemented through private, local, state
and tribal partnerships, with the goal of: preserving,
restoring.... ecosystem integrity... that also maintains the
possibility of sustainable societies and economies.
-------
Principles of w r r c
Ecosystem
Management
Margaret A. Moote
Sabrina Burke
Hanna J. Cortner
Mary G. Wallace
January 1994
This document summarizes the. first phase cf an analysis of the mstttutumal
barriers and Incentives to ecosystem management. A resnev, cf the ecosystem
management literature found five principles */ ecosystem management. The
UterL-e search included writings in the areas of adaptive management
conservation biology, ecosystem management, integrated environmental
management, and a miscellany of social science literature.
-------
Ecosystem management is a management philosophy which focuses on desired states, rather
than system outputs, and which recognizes the need to protect or restore critical ecological
components, functions, and structures in order to sustain resources in perpetuity.
finally Define Goals and Manaeement Objectives
Desired future conditions and the means by which we choose to achieve these conditions are
social values. Therefore ecosystem management, like all forms of management, is a socially
defined process. There is nevertheless a recognized need for human society to adapt its
activities to protect crucial ecological processes.
Inters Holistic Science
Ecosystem management uses a holistic approach, rather than focusing on specific system
outputs. It attempts to conserve biodiversity from the genetic to the community level.
Ecosystems are recognized as open, changing, complex systems. Ecosystem management
focuses on the dynamic interrelations of systems components—including social, political,
economic, biological, and physical features-and requires better understanding of each of
these components and their interrelations. Humans are recognized as a part of ecosystems.
Sngfifl? and Tenrooral Scales
Specific of management will be determined individually for each system, based on
values and goals. In general, however, ecosystem management requires management
on larger spatial and longer temporal time scales than has been the norm in resource
management. Ecosystem management means management across ecological, political,
generational, and ownership boundaries.
^flhnffltjvft TVSrffffl Building
Successful planning for ecosystem management must be sensitive to the different mandates,
objectives, and constituencies of agencies and landowners. Therefore, there is a need for
cooperative, integrated data collection and planning, characterized by open communication
among scientists, resource management agencies, and private interests. Participants should
strive for joint organizational and community learning that acknowledges the values and
expertise each participant brings to the planning process.
Institutions /
Institutions for ecosystem management must reflect its experimental nature. Organizations,
laws, poling, and management practices need to be flexible, in order that they may adapt to
changes in social values, environmental conditions, political pressures, available dak, and
knowledge. Adaptable institutions treat management as a learning process in which decisions
are continuously revisited and revised, and therefore allow planning and decision-making to
go forward in the face of uncertainty. At the same time, it is recognized that institutional
decision-making is bounded by the currently defined legal limits of planning and management
and by socio-political factors.
1
-------
Definitions of Ecosystem Management
"Ecosystem management involves regulating internal ecosystem structure and function plus
inputs and outputs, to achieve socially desirable conditions" (Johnson and Agee, 1988. p.7).
"[Ecosystem management] means that we must blend the needs of people and environmental
values in such a way that the National Forests and Grasslands present diverse heaithv
productive, and sustainable ecosystems" (Robertson, 1992, p.l). '
"The approach is characterized by synthesis or integrated knowledge, a holistic perspective
interrelating systems at different levels of integration, and actions that are ecological
anticipatory, and ethical in respect to other systems of Nature" (Q. Francis, 1993, p.33l)
Goals of ecosystem management include "caring for the earth by... Sustaining healthy
ecosystems. Maintaining the integrity of ecosystems to the extent possible. Modifying
ecosystem function, structure, and composition as desired to sustain rare ecosystems and
their components; and to ensure ecosystem viability indefinitely" (Iverson, 1993, p.2).
"Ecosystem management focuses on the conditions of the [ecosystem], with goals of
maintaining soil productivity, gene conservation, biodiversity, landscape patterns, and the
array of ecological processes" (SAF Task Force, 1992, pp.iv-v).
"Take care of the land' by protecting or restoring the integrity of its soils, air, waters,
biological diversity, and ecological processes" (Robertson, 1992, p.2).
"We propose that ecosystem management is management of natural resources using systems-
wide concepts to ensure that all plants and animals in the ecosystem are maintained at viable
levels in native habitats and that basic ecosystem processes (e.g., nutrient cycling) are
perpetuated indefinitely" (Clark and Zaunbrecher, 1987, pp.11-12).
•Ecosystem management is a process that considers the total environment. It requires the
skillful use of ecological, economic, social, and managerial principles in managing
ecosystems to produce, restore, or sustain ecosystem integrity and desired conditions, uses,
products, values, and services over the long term.... Ecosystem management recognizes that
people and their social and economic needs are an integral part of ecological systems"
(USDOI, BLM, 1993, pp.43208-43209).
"Ecosystem management focuses on the maintenance of an ecosystem's natural flows,
structures, and cycles, displacing the traditional emphasis on the protection of such individual
elements as popular species or natural features" (Goldstein, 1992, p. 184).
2
-------
Socially Defined Goals and Management Objectives
"People determine the goals that are at the heart of ecosystem management. Ultimately, we
shoulder the responsibility to live within the limits of our environment or to decide not to"
(Iverson, 1993, p.2).
"Ecosystem management seems to be not merely a technical concept, but a concept of land
management that is both a consequence and a determinant of social attitudes, values, and
institutions" (Clark and Mintra, 1993, p.48).
"Ecosystem management... should explicitly reflect multiple, measurable goals defining both
natural environmental conditions and socioeconomic concerns. These goals should
acknowledge the fact that social values, political pressures, and biological knowledge may be
different ten to twenty years from now" (Agee and Johnson, 1988, p.229).
"The best ecological approaches cannot sustain ecosystems unless they are integrated into a
human context" (Pfister, 1993, p.231)..
"Management... occurs by and through people and is thus inherently social and political.
Governments cannot realistically be expected to execute policies for which they feel no real
commitment. Elected and appointed officials are often reluctant to carry out policies which
they feel are disregarded, opposed, or not understood by influential constituents" (Caldwell,
1988, p. 16).
"Ecosystem management depends as much on social and political sensitivity as biological
knowledge" (Ouachita Forest staff member, quoted in Shands, et al., 1993, pp.9-10).
"[Questions of scale will only be understood if we accept that they involve value
judgements. The correct scale on which to address a management problem is determined by
what society wants to accomplish with that system" (Norton, 1992, p.36).
"The interests of scientists are usually quite narrow and reflect the particular history of a
discipline. There is thus no guarantee that in a scientific study the appropriate variables or
processes will be measured, or that information will be collected on the proper spatial and
temporal scales to address management questions. The research necessary for adaptive
assessment and design must be focused through policy concerns" (Holling, 1978, p.4).
"The implications are that in moving away from a narrow, anthropocentric, utilitarian
('resourcist') stance toward a more biocentric view of the world, management of ourselves
takes precedence over the manipulation of nature" (G. Francis, 1993, p.328).
3
-------
Integrated. Holistic Science
"Drawing heavily upon ecological and biological sciences, particularly the field of
conservation biology, ecosystem management views the land and resource base in its
entirety, as a holistic or integrated entity. ...because ecosystem management draws heavily
upon scientific principles and research, it requires an improved understanding of ecological
systems so that management proposals can be defined to minimize disruption of natural
processes" (Keiter, 1993, p.l).
"[E]cosystem approaches have ... a basis in ecological and systems principles that better
integrate description, understanding, and prescription in complex scientific and professional
situations. They use a holistic, interdisciplinary systems perspective, seeking to place the
system of primary interest in larger context. Ecosystem approaches focus on interactions,
systems behavior, and changing patterns of structure and organization" (Slocombe, 1993b,
p.620).
To take an 'ecosystem approach* means that resource people shift their focus from parts to
wholes, from the 'interest' to the 'capital', from trees and other plants, animals, stream flow,
esthetics, and whatever else the earth's surface yields, to the three-dimensional landscape
ecosystems and waterscape ecosystems that produce these valuable things" (Rowe, 1992,
p.222).
"[BJecause ecological systems evolve over time, often unpredictably, ecosystem management
is intended to accommodate such instability and change" (Keiter, 1993, p.l).
"The ecosystem approach is holistic. It opposes the classical idea that the world can be
analyzed as separate, independent parts. These parts are seen to be intimately connected,
their dynamic relationships depending, in an irreducible way, on the state of the whole
system" (Thornis, Vallentyne, Ogilvie, and Kingham, 1988, pp.41-42).
"[A]n ecosystem approach must be not only ecologically sound but also economically viable
and socially responsible—if it is lacking in any one of these three areas the system will
collapse" (Sample, et al., 1993).
"Ecosystem management ...[mjeans taking an adaptive approach to management where we
use the best scientific knowledge and technologies, clearly recognize knowledge gaps, build
shared expectations among those who have a stake in ecosystem outcomes, monitor actions,
and adjust management actions accordingly" (Iverson, 1993, p.l).
"Ecosystem approach ... [is] [e]xplicitly holistic, transdisciplinary; seeking to integrate
biophysical and socioeconomic dimensions with input from many disciplines; ... [r]edefines
ecosystem naturally, includes people within it..." (Slocombe, 1993a, p.299).
4
-------
Broad Spatial and Temporal Scales
[Ecosystem management] ... differs from traditional approaches to land and resource
management... in that it incorporates a wider breadth of ecological and social concerns as
well as a longer time scale for productivity and renewability" (Salwasser, 1991, pp.252-253).
"An important aspect of sustainable ecosystem management is to maintain future
opportunities to manage for ecological objectives" (Swanson and Franklin, 1992, p.271).
"Ecosystems should be viewed at a range of spatial scales, from global to local. Geographic
context influences ecosystem variability at all levels. ... Ecosystem management must be
guided by an understanding of natural and human-induced variability occurring in an area
over time" (Iverson, 1993, p.3).
"Processes appear linear and states constant only over a limited spatial and temporal field.
We must emphasize the placing of forest landscape objectives in a larger context in both
space and time" (Mladenoff and Pastor, 1993, p. 158).
"Every system definable in biological and physical terms connects to and interacts with a
network of human values, uses, institutions, and other social structures. ...EM tracks
transactions across defined system boundaries and moves the boundaries themselves when
necessary" (Gordon, 1993, pp.242-243).
"[W]e must take special care ... to avoid near term resource management decisions that may
overly restrict or foreclose future management options" (Sample, et al., 1993, p. 6).
"[EJncourage the development of integrated classification schemes, inventory methods, and
data management systems for various levels of resolution and aggregation that allow data
analysis and interpretation at landscape and bioregional levels" (SAF Task Force, 1992, p.
120).
"The goal of preserving diversity at all levels-genes, species, and ecosystems-requires a
better understanding of how ecological processes operating on different spatial and temporal
scales interact" (Ecological Society of America, 1991, p.389).
5
-------
Collaborative Derision Building
"There can be no lasting solution to ecosystem and natural resource management problems in
democratic societies except through a joint planning approach... The very nature of
ecosystems dictates that broad, cooperative, and integrated approaches to ecosystem
management have to be developed" (Gilbert, 1988, p.182).
"For sustainable management, cooperation needs to be an interactive process that includes all
players. ... Interagency cooperative frameworks that fail to address who participates in
decision making and how decisions are made are not likely to succeed" (Grumbine, 1991,
P-31).
"Since water, plants, animals, pollutants, and people are in large part oblivious to
administrative boundaries and cross them at will, ecosystem management combined with
decentralized and fragmented decision-making structures will intensify the need for
coordination among land and water management agencies at all levels of government"
(Conner and Moote, 1994).
"We cannot conceive of any way in which an 'ecosystem' approach could be implemented in
jurisdictions with opposing attitudes, institutions, laws, and behaviours-except perhaps in an
altruistic spirit of dedicated cooperation" (Vallentyne and Beeton, 1988, p.61).
"The lack of commonly held policy and management goals among the agencies is the single
greatest impediment to sound ecosystem coordination ... The crushing complexity of
coordinating management activities between scores of separate political ami administrative
entities looms as the second most important challenge" (Variey, 1988, p.220).
"Everyone plays a role in ecosystem management. We must... develop shared landscape
expectations with the public to address people's needs and desires for present and future
generations. Share information and data bases for all lands to integrate our evolving
scientific knowledge into management plans and projects. Integrate biological, social, and
physical sciences to achieve sustainability and equity in management decisions. Create
organizational environments in harmony with ecosystem management, restructured with
goals, incentives, and rewards that move us collectively toward desired ecosystem and social
system outcomes" (Iverson, 1993, p.4).
"More than ever, management of public lands and resources requires knowledge about
ecosystems, including relationships to human values, activities, and patterns of resource use.
Also required are new roles for scientists, including closer partnerships with managers to
achieve large-scale studies and adaptive management of public lands and resources" (Kessler,
et al., 1992, p.221).
6
-------
Adaptable Institutions
"A seemingly unrecognized dimension is the extent to which institutional arrangements limit
the ability of scientists and scientific institutions to focus on relevant research leading to the
technical resolution of environmental problems. Cqmpartmentalization is often associated
with rigid interpretations of 'missions' or 'mandates' as expressed by legislation or
regulations which authorize programs" (Caldwell, 1988, p.4).
"Applying concepts of dynamic landscape heterogeneity...requires changes at the policy and
planning levels, where entire national forests or state forest ownerships are placed in broader
frameworks" (Mladenoff and Pastor, 1993, p. 163).
"Adapting to change means adapting to the unknown: it requires flexible institutions to cope
with uncertain risks" (Grzybowski, A.G.S. and D.S. Slocombe, 1988, p.474).
"[Adaptive management] begins with the central tenet that management involves a continual
learning process that cannot conveniently been separated into functions like 'research' and
'ongoing regulatory activities' and probably never converges to a state of blissful equilibrium
involving full knowledge and optimum productivity" (Walters, 1986, p.8).
"No set of goals should be so firmly adopted that institutional adaptability is lost" (Agee and
Johnson, 1988, p.229).
"Given the complexities and uncertainties inherent in the biophysical and social systems that
make up ecosystems, sustainable management can only be achieved if management
institutions have strong social learning capacities" (McLain, 1993, Executive Summary).
"Ecosystem management... is about institutional change in the Forest Service. Rather than a
set of well defined practices, [it is] about processes for change" (Shands, et al., 1993, p.4).
"When extended to guiding planning and management interventions, an ecosystem approach
uses analyses of actors and institutions to recommend or facilitate more consensual,
participatory processes; cognitive or perceptual shifts; and institutional integration"
(Slocombe, 1993b, p.620).
"A paradigm shift to actual ecosystem-level management will not be possible under the
existing management structure, which divides land and water along political boundaries and
sections ecosystems into commodity resources" (Conner and Moote, 1994).
"We should study how human institutions deal with the interdependence created when human
boundaries cut across ecological continuities" (K. Lee, 1993).
7
-------
references
Agee, James K. and Darryll R. Johnson. 1988. A direction for ecosystem management.
Pages 226-232 in: Agee, James K., and Danyll R. Johnson, Editors. Ecosystem
Management for Parks and Wilderness. Seattle: University of Washington Press.
Alston, Ricnara M. 1991. Are sustained yield and sustainable forests equivalent? Pages 310-
315 in: Proceedings. 1991 SAF National Convention, August 4-7, 1991. Bethesda, MD:
Society of American Foresters.
Aplet, Gregory H. and Nels Johnson. 1993. Designing sustainable ecological systems: a
regional approach. Pages 123-126 in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson,
and V. Alaric Sample, Editors. Defining Sustainable Forestry. Covelo, CA: Island Press.
Bates, Sarah. 1993. Discussion paper: managing for ecosystems on the public lands.
Natural Resources Law Center. University of Colorado School of Law. Western Lands
Report No. 4.
Bennett, John W. 1990. Ecosystems, environmentalism, resource conservation, and
anthropological research. Pages 435-457 in: Emilio F. Moran, Editor. The Ecosystem
Approach in Anthropology. Ann Arbor: The University of Michigan Press.
Bormann, B.T., M.H. Brookes, E.D. Ford, A.R. Keister, C.D. Oliver, J.F. Weigand. 1993.
A broad, strategic framework for sustainable-ecosystem management. Document prepared by
the Eastside Forest Health Panel for presentation to the Chief of the USDA Forest Service in
May 1993. Corvalis, OR: Forestry Sciences Lab. 62 pp.
Born, Stephen M. and William C. Sonzogni. 1993. Integrated environmental management:
strengthening the conceptualization. Unpublished manuscript. Madison, WI: University of
Wisconsin, Urban and Regional Planning.
Cairns, John Jr. 1991. The need for integrated environmental systems management. Pages •
5-20 in: John Cairns, Jr. and Todd V. Crawford, Editors. Integrated Environmental
Management. Chelsea, MI: Lewis Publishers..
Caldwell, Lynton K. 1970. The ecosystem as a criterion for public land policy. Natural
Resources Journal. 10(April, 1970): 203-221.
Caldwell, Lynton K. 1988. Implementing an ecosystems approach. Pages 1-29 in: Caldwell,
Lynton Keith, Editor. Perspectives on Ecosystem Management for the Great Lakes: A
Reader. Albany, NY: State University of New York Press.
Clark, Tim W., Elizabeth Dawn Amato, Donald G. Whittemore, and Ann H. Harvey. 1991.
Policy and programs for ecosystem management in the greater Yellowstone ecosystem: an
8
-------
analysis. Q^rvatiorr Biology. 5(3):412-422.
Clark, Tim W. and Ann H. Harvey. 1990. The greater Yellowstone ecosystem policy arena.
Society and Natural Resources. 3:281-284.
Clark, Tim, and Steven Minta. 1993. Greater Yellowstone's Future: Prospects for
Ecosystem Science. Management, and Policy. Moose, WY: Homestead PuMishing. (In
manuscript, 148 pp.).
Clark, T.W. and D. Zaunbrecher. 1987. The greater Yellowstone ecosystem: the ecosystem
concept in natural resource policy and .management. Renewable Resources Journal. 5(3):8-
16.
Cortner, Hanna J. and Margaret A. Moote. 1994. Trends and issues in land and water
resources management: setting the agenda for change. Environmental Management. 18:
forthcoming.
Cortner, Hanna J. and Margaret A. Moote. 1992. Sustainability and ecosystem management:
forces shaping political agendas and public policy. Pages 310-316 in: American Forestrv-
An Evolving Tradition. Proceedings of the Society of American Foresters National
Convention. Bethesda, MD: Society of American Foresters.
Costanza, Robert. 1992. Toward an operational definition of ecosystem health. Pages 239-
256 in: Costanza, Robert, Bryan G. Norton, and Benjamin D. Haskell, Editors. Ecosystem
Health: New Goals for Environmental Management. Covelo, CA: Island Press.
Ecological Society of America. 1991. The sustainable biosphere initiative: an ecological
research agenda. Ecology. 72(2):371-412.
Faber, Malte, Reiner Manstatten, and John Proops. 1992. Toward an open future:
ignorance, novelty, and evolution. Pages 77-96 in: Costanza, Robert, Bryan G. Norton,
and Benjamin D. Haskell, Editors. Ecosystem Health: New Goals for Environmental
Management Covelo, CA: Island Press.
Francis, George. 1993. Ecosystem management Natural Resources Journal. 33:315-345.
Francis, George R. 1988. Great Lakes governance and the ecosystem approach: where next?
Pages 319-343 in: Lynton K. Caldwell, Editor. Perspectives on Ecosystem Management for
the Great Lata*. Albany, NY: State University of New York Press.
Francis, John. 1990. Natural resources, contending theoretical perspectives and the problem
of prescription. Natural Resources Journal. 30(2):263-283.
9
-------
Franklin, Jerry F. 1993. Preserving biodiversity: species, ecosystems, or landscapes?
Ecological Applications. 3(2):202-205.
Franldin, Jerry F. 1993. The fundamentals of ecosystem management with applications in the
Pacific Northwest. Pages 127-144 in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson,
and V. Alaric Sample, Editors. Defining Sustainable Forestry, Covelo, CA: Island Press.
Franklin, Jerry F. 1992. Forest Stewardship in an Ecological Syracuse, NY: State
University of New York College of Environmental Science and Forestry, Faculty of Forestry
Miscellaneous Publication Number 27.
Gilbert, Vemon. 1988. Cooperation in ecosystem management. Pages 180-192 in: Agee,
James K., and Darryll R. Johnson, Editors. Ecosystem Management far ^
Wilderness. Seattle: University of Washington Press.
Goldstein, Bruce. "1992. The struggle over ecosystem management at Yellowstone.
Bioscience. 42(3): 183-187.
Gordon, John C. 1993. Ecosystem management: an idiosyncratic overview. Pages 240-244
in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson, and V. Alaric Sample, Editors.
Defining Sustainable Forestry. Covelo, CA: Island Press.
Grumbine, R. Edward. 1991. Cooperation or conflict? Interagency relationships and the
future of biodiversity for U.S. parks and forests. Environmental Management 15(l):27-37.
Grumbine, R. Edward. 1990. Protecting biological diversity through the greater ecosystem
concept. Natural Arg^fi Tnnraal. 10(3): 114-120.
Grumbine, R. Edward. 1990. Viable populations, reserve size, and federal lands
management: a critique. Conservation Biology. 4(2): 127-134.
Grzybowski, Alex, and D. Scott Slocombe. 1988. Self organization theories and
environmental management: the case of South Moresby, Canada. Environmental
Management. 12(4):463-478.
Holling, C.S., Editor. 1978. Adaptive Environmental Assessment and Mgn^rTT1?nT
London: John Wiley and Sons. 377 pp.
Institute for Forest Analysis, Planning, and Policy. 1992. The Duluth Manifesto: PrinCT>i«
tn fruirie on Forests. Baltimore, MD: Institute for Forest Analysis, Planning, and
Policy.
Iverson, Dave. 1993. Framework for a shared approach to ecosystem management.
Unpublished draft. September 1, 1993.
10
-------
Johnson, Danyll R. and James K. Agee. 1988. Introduction to ecosystem management.
Pages 3-14 in: Agee, James K., and Danyll R. Johnson, Editors. Ecosystem Management
for Parks and Wilderness. Seattle: University of Washington Press.
Jones, Steve M. and F. Thomas Lloyd. 1993. Landscape ecosystem classification:. the first
step toward ecosystem management in the southeastern United States. Pages 181-201 in:
Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson, and V. Alaric Sample, Editors. Defining
Sustainable Forestry. Covelo, CA: Island Press.
Keiter, Robert B. 1993. Beyond the boundary line: ecosystems and law on the public
domain. Paper presented at "A New Era for the Western Public Lands", conference at
Natural Resources Law Center, University of Colorado, Boulder, Colorado, September 19-
21, 1993.
Keiter, Robert B. 1988. Natural ecosystem management in park and wilderness areas:
looking at the law. Pages 15-40 in: Agee, James K., and Danyll R. Johnson, Editors.
Ecosystem Management for Parks and Wilderness. Seattle: University of Washington Press.
Keiter, R.B. and Boyce, M.S. 1991. Greater Yellowstone's future: ecosystem management
in a wilderness environment. Pages 379-413 in: R. Keiter and M.S. Boyce, Editors. The
Greater Yellowstone Ecosvwi Apnroachffs to Resource Planning and Management. Calgary, Alberta:
The Banff Centre for Continuing Education.
Lee, Kai N. 1993. and Gyroscope: Integrating Science and the Environment
Covelo, CA: Island Press. 243 pp.
Lee, Robert G. 1992. Ecologically effective social organization as a requirement for
sustaining watershed ecosystems. Pages 73-90 in: R.J. Naiman, Editor. Watershed
Management: p^neine Su^inahilitv and Environmental Change. NY: Springer-Verlag.
McLain, Rebecca. 1993. Toward more effective ecological learning: procedural guidelines
for the USMAB landscape sustainabiBty project. Draft Manuscript. Seattle: University of
Washington, College of Forest Resources. 47 pp.
Mitchell, Bruce. 1986. The evolution of integrated resource management. Pages 13-26 in:
Reg Lang, Editor, integrated Approaches to Resource Planning and Management. Calgary,
11
-------
Alberta: The Banff Centre for Continuing Education.
Mladenhoff, David J. and John Pastor. 1993. Sustainable forest ecosystems in the northern
hardwood and conifer forest region: concepts and management. Pages 145-180 in: Aplet,
Gregory H., Nds Johnson, Jeffrey T. Olson, and V. Alaric Sample, Editors. Defining
Sustainable Forestry. Covelo, CA: Island Press.
Norton, Bryan G. 1992. A new paradigm for environmental management Pages 23-41 in:
Cnttanra, Robert, Bryan G. Norton, and Benjamin D. Haskell, Editors. Ecosystem Health;
New Goals for Environmental Management. Covelo, CA: Island Press.
Noss, Reed F. 1993. Sustainable forestry or sustainable forests? Pages 17-43 in: Aplet,
Gregory H., Nds Johnson, Jeffrey T. Olson, and V. Alaric Sample, Editors. Defininy
Sustainable Forestry. Covelo, CA: Island Press.
Orians, G.H. 1990. Ecological concepts of sustainability. Environment. 32(9): 10-15,34-39.
Pfister, Robert D. 1993. The need and potential for ecosystem management in forests of the
inland west. Pages 217-239 in: Aplet, Gregory H,y Nels Johnson, Jeffrey T. Olson, and V.
VAitnr* Mning Sustainable Forestry. Covelo, CA: Island Press.
Reidel, Cari, and Jean Richardson. 1992. A Public/Private Cooperative Paradigm for Federal
Land Management Pages 145-168 in: Congressional Research Service. Multiple ti«-
Sustained Yield; Changing Philosophies for Federal Land Management Washington, D.C.:
Government Printing Office.
Robertson, Dale. 1992. Memorandum issued to regional foresters and research-station
directors, June 4, 1992.
Romm, Jeff. 1993. Stuttinable forestry: an adaptive process. Pages 280-293 in: Aplet,
Gregory H., Neb Johnson, Jeffrey T. Olson, and V. Alaric Sample, Editors. Defining
Sustainable Forestry. Covelo, CA: Island Press.
Rowe, J. Stan. 1992, The ecosystem approach to forestland management. The Forestry
Chronicle. 68(2):222-224.
Salwasser, HaL 1992. the offidal story: new realities in the Forest Service. Timer Voiee.
4(4):4. puly/August).
Salwasser, HML 1991. In seardrof an ecosystem approach to endangered spteies
conservation. Pages 247-265 in; Kohm, Kathryn A., Editor. Balancing mi rh« Tvini, ^
Frtinerion; th» Endangered Species Act and T esions fnr the Future. Covelo, CA: Island
Press.
12
-------
Salwasser, Hal, Douglas W. MacCleery, and Thomas A. Snellgrove. 1993. An ecosystem
perspective on sustainable forestry and new directions for the U.S. national forest system.
Pages 44-89 in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson, and y. Alaric Sample,
Editors. Defining Sustainable Forestry. Covelo, CA: Island Press.
Salwasser, H, C.M. Schonewald-Cox, and R. Baker. 1987. The role of interagency
cooperation in managing for viable populations. Pages 159-174 in: Soule, M.E., Editor.
Vhhfc ftmuhtion. far rnM^vMiai. New Yoric Cambridte University Preu.
Sample, V. Alaric. 1992. Building partnerships for ecosystem management on forest and
range lands of mixed ownership. Pages 334-339 in: AfTlcnCflfl Forestry—An Evolving
Tradition. Proceedings of the Society of American Foresters National Convention.
Betheada, MD: Society of American Foresters.
Sample, V. Alaric, Nels Johnson, Gregory H. Aplet, and Jeffrey T. Olson. 1993.
Introduction. Pages 3-10 in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson, and V.
Alaric Sample, Editors, defining Sujftajn?^* Forestry. Covelo, CA: bland Press.
Shands, William E., Anne Black, and Jim GUtmier. 1993. From New Perspectives to
Ecosystem Management: A Report of an Assessment of New Perspectives. Milford, PA:
The Pinchot Institute for Conservation.
ShariB, R.R., L.R. Boring, D.H. Van Lear, and J.E. Pinder, in. 1992. Integrating
ecological cwwfpts with natural resource management of southern forests. Ecologies!
Applications. 2(3):226-237.
Slocombe, D. Scott. 1993a. Ecosystem approaches for sustainability. Ecosystem
Management- 17(3):289-303.
Slocombe, D. Scott. 1993b. Implementing ecosystem-based management: development of
theory, practice, and research for planning and managing a region. Bioscience- 4(9).612-
622.
Society of American Foresters. 1992. Sustaining l
-------
Toman, Michael A. 1993. Defining an economic of sustainable forestry: general comments.
Pages 270-279 in: Aplet, Gregory H., Nels Johnson, Jeffrey T. Olson, and V. Alaric
Sample, VAitrm Defining Sustainable Forestry. Covelo, CA: Island Press.
U.S. Department of the Interior, Bureau of Land Management. 1993. Grazing administration
regulations, proposed rale, federal Register 58(155):43208-43231. August 13, 1993.
Vallentyne, J. and A. Beeton. 1988. The 'ecosystem' approach to managing human uses and
abuses of natural resources in the Great Lakes basin. Environmental Conservation 15:58-
62.
Vaiiey, John D. 1988. Managing Yellowstone National Park into the twenty-first century:
die paxic as an aquarium. Pages 216-225 in: Agee, James K., and Darryll R. Johnson,
Editors. Ber«v«tem Man^^ent for Parla and Wilderness. Seattle: University of
Washington Press.
Walters, Carl. 1986. Arrive Management of Renewable New York:
Macmillan. 374 pp.
14
-------
a components, structures and
lirocesseiBHHHHH
perpetuity.
-------
EPA AND ECOSYSTEM PROTECTION
EPA is a regulatory authority, not a Iand^n)uiage^nent authority. ^
EPA's role and authorities include public an<(j)^vat(
EPA asks different
main job is protection - no Competing m
-------
WATERSHED PROTECTION APPROACH
Key Principles
Problem Identification: identify primafy^hrea
Stakeholder Involvement: involve stakehol
concerned and most able to take action.
_n
Integrated Actions: take <
integrated manner once s
and refine actions as necc ssary.
orrective aci
tlutions are
comprelfemive,
ied*jEvalu3fe success
-------
WATERSHED PROTECTION APPROACH
Key Characteristics
¦ Realignment of traditional regulatory
to support integrated watershed m
latory program^
Provides a way to leverage EPA and non-EPA efforts^o pr
coordinated and system-based jratershed management
\ jam
n.
EPA's roles can vary de[ ending on ci
convener, approver, supporter, coord]
implementer.
u
r, p^oter and
a
-------
CLEAN WATER ACT
Gives broad authority to protect the chemical, physical, and biological
D
integrity of the nation's waters
Wetlands
Non-point Source Program
NPDES
Standards
-------
^ The Emerging Water
Quality Program
CWA Goal:
Aquatic Ecosystem
Integrity
Water
Resource
Criteria for
Protection
Water Quality
Standards
Coordination
Framework
Watershed
Protection Approach
Water Quality Management
Programs, Tools, and Resources
-------
^ NPDES Watershed
Strategy: Components
• Statewide coordination
• NPDES permits
• Monitoring and assessment
• Programmatic measures and
environmental indicators
• Public participation
• Enforcement
-------
NPDES Watershed
Strategy: Objectives
Eliminate or reduce program-
related impediments to WPAs
Allocate program resources to
achieve greatest environmental
benefit
Use compliance monitoring
and enforcement to further
WPA objectives
Coordinate with others to
implement basin management
frameworks
Support related activities that
address basin priorities
-------
How Can NPDES Programs
Benefit from the WPA?
Increased focus on
environmental results
Improved basis for decisions
Enhanced program efficiency
Improved coordination among
agencies
Resources better directed to
priority issues
Public support for decisions
-------
Figure 2.4
Birds Mammals Reptiles Amphibians Fishes Crayfishes Mussels
Sourvmx Th# Nitur* Conservancy, Bktdtvmntty Nmtwork Nmmr* 3, no. 3 (19SO>: 7.
from The Clean Water Act: 20 Years Later, by Robert W. Adler, Jessica C.
Landman, and Diane M. Cameron, 1993, Island Press, p. 60.
-------
CLEAN AIR ACT
Prevention of Significant Deterioration Program for Class I
Maintains ecological integrity of specifiep national ps|rks and
wilderness areas, i.e. Mt. Zirkel.
Non-attainment Areas:
State permitting authority has flexibility to rfenjuire
processes and control techniques if the environmen
outweigh the benefits of permitfink proposed source
Pollution Source(s): ^
EPA has authority to brin g suit or iss
or other action if the sour
stop emissions.
:e(s) present! 11 an imminfent and substantial
endangerment to public health(g^yelfare, or the environment."
-------
FIFRA
EPA may grant or deny registration of a
"unreasonable adverse effects on the environm
ding effects
on ecosystems, by prohibiting or restricting use of a pesIM^le in ^specific
area. ^
^_T
D C
U
-------
TSCA
c
Broad authority to collect information in determining wii
manufacture, processing, distribution or "mixtur^presefcjts an un
ther^the"
adverse risk of injury to an ecosystem.
O
^j
onable
-------
EPCRA
Can affect the chemicals identified for reporting a LJaki
toxic releases and ecological concerns into account in developing en^jrgency
response plans. ~-v
-------
RESOURCE CONSERVATION
AND RECOVERY ACT
-------
CERCLA
Can be used to support coordinated ecosyst ;m protection efforts
Ecological impacts could be considered }o greater extent ^Ts^ttin ;
priorities (rulemaking would be required 10 chajige hazard ranking
system used in placing sites on the NPL). ^
Selection of remedies could be flriyen more by ecolo;
Ecological Risk Assessmen s could be bfroad
ical impacts
~U~
c
u
-------
SAFE DRINKING WATER ACT
Sole source aquifer program - provides
aquifers that serve as critical sources of drii(kh)g ws
Protection of watersheds t
-------
NATIONAL ENVIRONMENTAL POLICY ACT
Requires EPA to examine "effects" 9 both direct and
actions as tliey relate to "...air and watar and other
including ecosystems.11 \^J
ndinecK of I
lablpalkste
Particularly applicable to Regiofach because of signifi
federal land (33%). "
u
u
n
deral
US,
ige of
-------
NATIONAL ENVIRONMENTAL POLICY ACT
£PA (in collaboration with other agencies) cuuld devetap
guidance for NEPA reviewers that directs federal agenj
systematically analyze effects of proposed federal ac
and ecosystem health
explore opportunities to support sustainable econom,
and communities \ }
—u
explore opportunities to coordinate with ot^er federal agencies
and the non-federal community at the eposysrfeih scale
versity
-------
NATIONAL ENVIRONMENTAL POLICY ACT
EPA (in collaboration with other agencies) iould develop!
guidance for NEPA reviewers that directs fraeral agomies to:
D
consider established federal or non-fedeJaLerosystem mamgdmsn
objectives
b c
relv on sound ecological, economic and social science
—
c
analyze opportunities to utilze adaptive [nan^gapent
u
approaches
-------
ENDANGERED SPECIES ACT
" The purposes of this Act are to provideralneans whfcreb;
ecosystems upon which endangered specsiaud tlmleiid
species depend may be conserved.
11 It is further declared to b
departments and agencies si
threatened species and shall
of the purposes of this Act.1
ouny uf Guiigresartf
all seek to cwiseiWenda
utilize their
lgereojETpecies and
oriti^sm furtherance
-------
ENFORCEMENT
Integration of enforcement activities
Cleanup activities under CERCLA andlNRDA progjamsi )
Supplemental Environmental Projects (SEP)
Target areas for enforcemi nt based on Lcold^ic^l co
Multi-Media
-------
GRANTING AUTHORITIES
Clean Water Act
Support continuing Environmental P
media-specific authorities
Multi-media grant authqritieT^ ^
National Environmental Education Act^ ^
-------
ENVIRONMENTAL PROTECTION - TOOLS
-------
ENVIRONMENTAL PROTECTION - TOOLS
¦ Spatial Tools
Ecoregions
GIS
¦ Environmental Indicators
¦ Ecological Risk Assessment
-------
ECOREGIONS
After Omernik 1987
Partition landscape into areas of greater homogeneity
Spatial framework for environmental resource jnaytag ement
Based on landscape-level features
Geomorphology
Geology
Soils
Land use
Subi
-------
ENVIRONMENTAL PROTECTION - TOOLS
Hierarchy of Ecosystem Scales
Region
Landscape
Stand/Site
Watershed
Soutce-. Adapted horn jalwasset, "Correct vtng B\o\og\ca\ Olvets\ly*. /V Petspeclwe o\. jpe
\ • r- « r- * • % ¦ «
-------
/
:
(
c
i
(
»!
: i
' I
!i
S;
9
l)
n !
o
f'
5l
z *
11
3" i
\ !
*¦ i
?-1
3 *
Si
EPA Region VIII
USGS Basin Boundaries
-------
EPA Region VIII
Colorado Ecoregions
¦ v>s k # . v ^ 1'?H3:35
ED Wyoming Basin
1 ,
1 1
L 1 Colorado Plateaus
•'ctlpS
38 " "^n. '<$$ ' ' *£¦•
•w«y
fiaaS
ivtti&tsbiil
¦mm-
¦ y. •; ;¦:¦¦<>• -*S
$SM¥*&
w:HSj:«*;; r:;: #*£**: i i'. ft#;»ftj •
„«¦> iinT;
»»
¦sm-
•v
. . ;¦:«<
ESS Southern Rockies
i—i
i i Arizona/New Mexico Plateau
•—»'• • • '•'»• :'N< <-*»«^ v;5^,.:V.iy ;•:
• •»' * VV, . " . . *.:
'¦ . . ¦..•¦ :•;« •
~*$#> *"s ¦¦ ' • '**• - ¦-
Western High Plains
~ •... • •
Southwestern Tablelands
a*"
*, y
** ...t*'
-------
EPA Region VIII
Colorado Sub-Ecoregions
Wyoming Basin
Colorado Plateaus
Southern Rockies
Arizona/New Mexico Plateau
Western High Plains
Southwestern Tablelands
-------
EPA Region VIII
Land Ownership and Political Boundaries
¦
blm mm pod
"Tribes
jju - - jjft -
2 -t : < ? l'„'/ ~
Other Federal
-------
ENVIRONMENTAL INDICATORS
Top Ten Reasons to Develop/Implement Ecological Indicators
10) Beyond Point Source Control
9) Cost Effective
8) Identify New & Emerging Problei
7) Direct Measures of Agency/Regional
6) Integrate Variety of Programs
5) Meet Government Performance and Results Act Requirements
4) Measure Program Effectiveness - (investment/disinvestment)
3) Agency Strategic Goal - better science & public decision-making
2) Communication "customers11 (Political, Other Agencies, Public)
1) Our
-------
ENVIRONMENTAL INDICATORS
7) Direct Measures of Agency/Regional Mission
BIOASSESSMENT DECISION CRITERIA
Example Biological Condition
Criteria (a) Category
>83% Non-Impaired
54-79% Slightly Impaired
21-50% Moderately Impaired
<17% Severely Impaired
(a) percent of reference
Attributes
Optimum community structure
(composition & dominance) for
stream size and habitat quality In
ecoregion.
Composition (species richness)
lower than expected due to loss
of some intolerant forms.
Percent contribution of tolerant
forms increases.
Fewer species due to loss of
important forms. Reduction in
EPT Index.
Few species present. If high
densities of organisms, then
dominated by one or two laxa.
-------
ENVIRONMENTAL INDICATORS
9) Cost Effective
RAPID BIOASSESSMENT CONCEPT - -
Level of Effort Comparison
Time Estimate (Work Hours/Station)
Traditional Sampling
Rapid Bioassessment
mm
0 1 2 3 4 5 6
Work Hours
7
-------
ENVIRONMENTAL INDICATORS
8) Identify New & Emerging Problems
10) Beyond Point Source Control
COMPARISON OF CHEMICAL CRITERIA EXCEEDANCES
AND BIOSURVEY RESULTS AT 413 SITES IN OHIO
36% CI>omicnl criteria iicScoto
no Inpalrmenl;
Blosurvey slwws
Impairment
6% Clwmlcal ciilotia
Indlcalg Impairment;
Blosurvey Indcates
no Impairment
Chomlcal prodcllon
and blosurvey agree
-------
ENVIRONMENTAL INDICATORS
National Goals Project (OWOW Sept. 1994)
Clean surface and Ground Wat
Support fishing, recreati
Pollutants
Biologically healthy wate
Wetlands
Groundwater quality
Safe Drinking Water
DW Standards violations
Contaminants causing violations
EPA and
life us is
-------
ENVIRONMENTAL INDICATORS
EPA and OW Strategic Goals |
~ DRAFT AGENCY GOALS* C
SAFE
DRINKING WATER
SAFE FOOD
1 OFFICE OF WATER GOALS laurtu ^
CLEAN WATER
ECOLOGICAL
PROTECTION
LOAD REDUCTION
Protect and Enhance
Public Health
(Meet Designated Uses)
Conserve and
Enhance Ecosystems <
(Meet Designated Uses)
Improve Ambient
Conditions
neduce Pollutant
Loadings
(Point and Non|>oinl
Sources)
Safe Drinking Wafer
Safe Fish and Shellfish Consumption
Sift Agnatic Recreation
llinlwgically lleallhjr Wafer Resources, Including
Lakes, lUrers, Sfreams, Estuaries, Coastal,Wafers,
Wetlands, and Vrsmd Water
Improved Surface Water Ambient Concentrations
of Toxic and Convent tonal Pollutants
(•round Waters Mccf Wafer Quality Objectives
No Net Loss of Wetlands
Extent or Contaminated Sediments Is Hcduccd
llcdnced Toxic rollutant Loadings
Reduced Conventional Pollutant Loadings
' Agency gods imtlar dcvrtnpnHStM
Olfico of Wafer
Enviioiwwntal Indicators
Fobruary 3. 1994
-------
ENVIRONMENTAL INDICATORS
EPA Technical Materials (Office of Water)
o Biological Criteria - Technical Guidance for Streams
and Small Rivers; OW, Sept. 1994
o Biological Criteria - Research and Regulation
Proceedings of the Symposium; OW, 1991
o Biological Criteria - Guide to Technical Literature;
OW, 1991
o Biological Criteria - State Development and
Implementation Efforts; OW, 1991
o Biological Criteria - National Program Guidance
for Surface Waters; OW, 1990
o Surface Water Monitoring: A Framework for
Change; OW, 1987
-------
ENVIRONMENTAL INDICATORS
"Biological Criteria - Technical Guidance for Streams and
Small Rivers" (OW, Sept. 1994)
CONTENTS
Chap. 1; Concept of Biocriteria
Characteristics, examples, references
Chap. 2: Components of Biocriteria
Conceptual framework, development
Chap. 3: The Reference Condition
Establishing, characterizing reference condition
Chap. 4: Conducting the Biosurvey
Quality Assurance Plan, Management of the program
Technical issues, standard methods
Chap. 5: Evaluating Environment Effects
Water quality, habitat
Chap. 6: Multimetric Approaches
Metrics for fish, macroinvertebrates
Chap. 7: Biocriteria Development and Implementation
Chap. 8: Applications
Case studies (N.Carolina, Ohio, Delaware, Maine)
-------
ECOLOGICAL RISK ASSESSMENT
Assessment Endpoints - actual environmental values to be protected.
Ecological relevance: e.g. change
abundance of many other species.
to control
Policy goals and societal values; val
endangered species protection to functitrfial
or aesthetic reasons.
Measurement Endpoint - a characteristic of an ecological system
that can be related to an assessment endpoint.
"Indicator1 - Wasures of
r?
eco
-------
ECOLOGICAL RISK ASSESSMENT
Consider effects beyond individuals of
community, ecosystem effects).
No single set of ecological values to be prot
scientific and policy based values).
ies (popu ation,
(include both
Increasing awareness of need to consider nonchemical as well as
chemical stressors.
-------
ECOLOGICAL RISK ASSESSMENT
"Because professional judgement is so inmortant9U|^ecializ<
and experience in the various phases offecologfcapr
assessment is required. Thus, an interactive lliullluisci
team that includes biologists and ecologists is a prerequisite
for a successful ecological risk assessment.11
d knowledge
•jiii
ary
Framework for Ecological Risk
Assessment; EPA, Feb. 1992
-------
ECOLOGICAL RISK ASSESSMENT
"Framework for Ecological Risk
(EPA Risk Assessment Forum, Feb. 1
Basic structure and consistent
for conducting and evaluating ecological
risk assessments.
"Ecological Risk Assessment Guidance for Superfund: Process
for Designing and Conducting Ecological Risk Assessments"
(EPA Emwrat^esponse Teasy. Sepk 1994, DRAFT)
cepted pcpcess fmconmcti||g ecological risk
assessment consistent with tWeeneral Framework.
-------
¦Implementation of ecosystem protection
principles will be complex and messy
¦ Ecosystem protection will require
leadership challenges, risk-taking,
flexibility, and mutual accountability
-------
RECOMMENDATIONS
Provide the ecosystem protection office with the authority and
resources to strategically plan, coordinate and target Region 8
resources on a geographic basis.
Closely affiliate the wa Eer^lj)ecl br^aii wit
programs.
¦ Support the develops
watershed and other s
H Target positions that a
mt andy^Qutlii^
rategi<
-------
ECOSYSTEM PROTECTION OFFICE
This office needs to be staffed with people who are knowledgeable about the workings of EPA's programs. Hie office needs
to have tlie authority and resources to coordinate EPA's resources and apply them based on established criteria to targeted areas.
Without the knowledgeable people and the authority, this will be an irrelevant office. By designing for multiple accountability and
several rotating positions in this office at least three benefits are realized: 1) career opportunities and interest are enhanced, 2)
program knowledge is updated, and 3) communication and support becomes mutual between this office and the implementing
programs.
CLOSE AFFILIATION
The watershed program, the flagship for ecosystem protection, and oilier such programs need close affiliation with the EPA
implementation programs. Programs providing grants and oversight to States in particular are programs with the potential to leverage
the principles of ecosystem protection and have had the experience of working on broad scales with multiple stakeholders. Multiple
accountability should be used to ensure close working relationships.
SUPPORT REGIONAL STRATEGIES
A regional watershed strategy is being developed at this time. Its development incorporates the needs we have identified for
successful ecosystem protection approaches based on direct experience with pilot projects and over 1.5 years of discussion. The needs
and actions were recommended from staff throughout the region. We recommend continued support and approval of these efforts
if ecosystem protection is to be meaningful. We also recommend that the watershed protection effort and the ecosystem protection
workgroup be folded together; too much unnecessary confusion and duplication exists because the watershed protection approach in
the Region is not officially recognized as a model of ecosystem protection. Other strategies could also become models as they are
developed.
CREATE POSITIONS WITH MULTIPLE ACCOUNTABILITY
Ecosystem protection, indeed reinvention, depend on leaky boundaries. We recommend tliat positions be targeted for
accountability to more than one ARAship. The watershed coordinator, for example, would be accountable to program(s) in both the
Ecosystem Protection and the Pollution Prevention ARAships. The G1S coordinator and other G1S experts would be accountable to
programs in both the Technical Assistance and Pollution Prevention, and perhaps Ecosystem Protection ARAships. Multiple
accountability occurs now; it should be used more creatively and to help create cross-program communication and coordination.
-------
RECOMMENDATIONS
Support the development of best science and explain how science
will be or has been used in decision-making.
Make management ad
feedback systems.
Recognize and encou
of roles EPA can pla;
Support staff time, tr lining a
designed
p reqsjste fonTj
with communities throughout the region.
U"
ravel to 4ork
-------
BEST SCIENCE
Development of scientific tools and knowledge must be envouraged, supported, enhanced and supported. This is one of EPA's
unique contributions to the federal team of agencies. We must be able to deliver on what we know — environmental assessment,
monitoring, tracking, data bases, indicators. We must continue to upgrade our technological capabilities. A core G1S expertise is
essential and currently inadequate. The GIS experts must be able to work closely project people regardless of the organizational
location of this expertise. Continued training in scientific methods and principles must be supported.
ADAPTIVE MANAGEMENT
Our institution must become more flexible and responsive to information which indicates that adjustments or wholesale changes
in approaches to program implementation should occur. We must establish well-designed feedback systems and continue to support
and expect monitoring programs so that we know when and why changes must occur. We must be especially careful to build in an
acknowledgement of adaptibility and expectation of further changes during reorganization. Organization based on predetermined
geographic areas must in particular have feedback mechanisms and inherent adaptibility in order to adjust to changing situations and
our experiences.
NEW AND CHANGING ROLES
Opportunities for additional roles for EPA exist during the implementation of ecosystem protection principles. EPA is being
looked to increasingly as a coordinator and facilitator of complex situations. But we must also recognize that very important roles
in technical assistance and as "invisible leader" continue and can be enhanced. Furthermore, our role must be able to change within
a given geognq>hic project as the activities move forward. We must be able to relinquish control or leadership as others take on the
responsibility of environmental protection.
TRAINING AND TRAVEL
Community approaches are simply not possible without the skills to work with people who have different perspectives to And
collaborative solutions. Training to develop skills for community-based environmental protection is necessary. We have
demonstrated that success requires our ability to be in the community at least once in a while. We must put a face on EPA. This
means travel funds msut be targeted towards putting staff "out there."
-------
RECOMMENDATIONS
Continue to encourage enhance and reward environmental
education work.
Adopt and deomonstr 11
Make performance
functions*
sU n
Help us make things
into energy drains anc
c asier - ajxumulljted iitfl^
id dlsuiusionment.
frustrations tu rn
-------
ENVIRONMENTAL EDUCATION
I know of no respository of the ultimate powers of society but the people themselves, and if we think them not enlightened enough
to exercise that control with a wholesome discretion, the remedy is not to take it from them, but to inform their discretion.
Thomas Jefferson, 1820
If EPA is truly going to work with communities of the public and bust in the public's discretion, we clearly need to continue
to enhance environmental education efforts. Without public understanding, knowledge, and, thus, support we guarantee our failure
to protect the environment and the public trust. We must also significantly improve our efforts to inform the public of the reasons
fin* our perspectives and decisions by using widely viewed media. We need to respond to attacks on our motives, our expertise, and
our intelligence. Not responding is not taking the higher ground but gives the appearance of guilt.
MUTUAL ACCOUNTABILITY AND TEAMWORK
A cultural paradigm shift must occur so that a culture exists in which high performance standards are applied and teams are
charged with decision-making and planning authority. Team members become accountable to each for producing a mutual product.
Failure is a team failure; success is team success - Mutual Accountability.
We must analyze our successes and failures with the team approach and incorporate lessons into our team efforts. We must
become familiar with the team process, and the difference between teams and workgroups. We must consciously determine whether
an effort is a team or workgroup effort and then base performance on our knowledge of the different processes.
HELP US MAKE THINGS EASIER
Accumulations of little frustrations lead to energy drains and disillusionment. For example, only one computer in the region
has Freelance for Windows and most people with home computus have more recent versions of the software. lumping between
various versions of software and vying for the computer whh others made preparing a briefing that was appealing and interesting
a frustrating experience. Someone decided that Senior Leadership briefing was not important enough to allow access to a color copier
to copy a few color pages for the notebooks.
-------
COMMUNITY-BASED ENVIRONMENTAL PROTECTION
Places have a way of claiming people. When they
claim very diverse kinds of people, then those people
must eventually learn to live with each other; they
must learn to inhabit their place together, which they
can only do through die development of certain
practices of inhabitation which both rely upon and
nurture the old-fashioned civic virtues of trust,
honesty, justice, toleration, cooperation, hope, and
remembrance. It is through the nurturing of such
values (and in no other way) that we might begin to
reclaim that competency upon which democratic
citizenship depends.
All ethics so evolved rest upon a single premise: that
the individudal is a member of a community of
interdependent parts. His instincts prompt him to
compete for his place in the community, buth his
ethics prompt him also to cooperate... The land ethic
simply enlarges the boundaries of the community to
include soils, waters, plants, and animals, or
collectively: the land.
Aldo Leopold
A Sand County Almanac
Daniel Kemmis
Community and the Politics of Place
-------
NEWS
¦ DEN » 1-10-95
"Some expect congress to pursup^Vsmaller CWA
agenda limited to funding and noBWntroversial statu-
tory modifications, while othen believe that major
amendments focusing on a^more flexible, less pre-
scriptive CWA could be eracted." CHS said.
CRS said the prosMCts for CWA remain uncertain,
since issues and controversies that stymied consider-
ation of the bill/in 1994 — including the so-called
regulatory relief and wetlands — are lilyrtrjto resur-
face in 1995/r ^ /
Concerns about unfunded mandates and risk/cost-
benefityanalyses may improvr*Congress' willingness
to tacioe reauthorization ojAhe SDWA in 1995, CRS
sail
ie 104th Congress/fa expected to consider two
sues related to RCHX reauthorization — interstate
waste transport and flow, control of munigjjial solid
waste — CRS sa^cf.
While Congress is expected to focttron oversight of
implementation of 1990 Clean ALT' Act amendments,
some legislative activity related to vehicle inspection
and maintenance and trip redactions could occur, CRSx^
said. / / X'
CRS'said it does not expect Congress to pass legisla-
tion/ dealing with .f(lobai climate change and
pesticides. /
/CRS, which is /part of the Library' of Congress,
provides inforn^ttion at the request congressional
committees, members of Congress; and their suffs.
Copies of ice report on existipf environmental laws,
^Summaijis of Environmental Laws Adminis-
tered hg the Environmental Protection Agency,
are available from BNA/Plus, telephone (800) 452-7773
or jOT2) 452-4323 in tire Washington area.
Text of the CBS^report dealing with the environ-
mental legislative agenda for the 104th Congress is in
Section E
Ecosystem Management
HATFIELD INTROOUCES BILL
TO DEFINE TERM, STUOY OPPORTUNITIES
The term "ecosystem management" would be de-
lined and an Ecosystem Management Study Commis-
sion would be created under to a bill (S 93) introduced
Jan. 4 by Sen. Mark Hatfield (R-Ore).
"Unfortunately, we as legislators and appropriators
understand little about this new and innovative land
management technique," Hatfield said in his introduc-
tion speech on the Senate floor.
"While [ecosystem management activity] is admira-
ble and perhaps necessary in the evolution of land
management policy, a great deal of apprehension and
concern still surrounds this method of managing our
water, air, land, and fish and wildlife resources on a
comprehensive scale." Hatfield added.
The proposed "Ecosystem Management Act of
1995" would amend the Federal Land Policy and
Management Act of 1976 by requiring a bipartisan
commission made up of members of the House and
Senate to submit a report one year after enactment.
The report wouid define ecosystem management,
identify opportunities for coordinated ecosystem plan-
ning, examine existing laws and federal agency bud-
gets to determine ways to facilitate ecosystem
management, and identify incentives to encourage
development of ecosystem strategies. The commission
would be assisted by an advisory committee appointed
by the Interior Department.
Hatfield described a history of ecosystem manage-
ment at the federal level, beginning with the 1992
release by the Interior Department's Bureau of Land
Management of resource management plans for west-
ern Oregon, which he said "developed the first com-
prehensive strategy for management of forest
ecosystems and watersheds in the nation."
Makeup Of The Commission
The Ecosystem Management Study Commission es-
tablished under the bill would be composed of the
chairman and ranking minority member (or their
designees) from the following Congressional commit-
tees: the Senate Energy and Natural Resources* Com-
mittee: the Senate Energy Committee's Subcommittee
on Public Lands. National Parks, and Forests; the
Senate Appropriations Committee; the Senate Appro-
priations Subcommittee on Interior; the House Natu-
ral Resources Committee; the House Natural
Resources Subcommittee on National Parks, Forests,
and Public Lands; the House Appropriations Commit-
tee; and the House Appropriations Subcommittee on
Interior..
Members of other committees — such as tip Senate
Environment and Public Works Committee and the
Senate Agriculture, Nutrition, and Forestry Commit-
tee — may be added to the commission's membership
as the bill goes through the hearing process, a Senate
staffer told BNA Jan. 9.
The bill would require the secretary of interior to
appoint 13 members to an advisory committee that
includes two tribal nominees, three nominees from the
Western Governors Association, two members of con-
servation groups, two members of industries with
public lands concerns, two members* of professional
societies familiar with the concept of professional
management, and two members of the legal communi-
ty.
One Agency's Current Definition
"Each federal government agency, state agency,
interest group and Congress-person has his or her own
idea of what ecosystem management means for the
people and ecology of their particular state or region."
Hatfield said on the floor of the Senate.
Elizabeth Rieben, a pubUc affairs specialist with
BLM. which oversees 270 million acres of public land,
provided BNA with materials including BLM's defini-
tion of ecosystem management: "In simple terms,
ecosystem management means keeping environments
healthy, diverse, and productive so people can benefit
from them year after year. For the BLM, this means
identifying limits to use and development of the land's
resources and managing within those limits in order to
ensure the long-term health and productivity of the
environment." The documents also include restoration
Copynqm 3 IMS tjy THE BUREAU OF NATIONAL AFFAIRS. INC.. Wasnington. O.C. 20037
10eo-2»78/9$/SO~Sl.OO
-------
NtWS
(NO. 6)
A - 5
of damaged land to a healthy condition within the
definition of ecosystem management.
The Clinton administration's f ®
Review's 1993 recommendations for reinventing gov-
ernment" included develop ^
planning and inMUKCinsoti A December 1994 General
Accounting Office Report r®vj?w®Jp^er^'r^ ®2*
ernment's implementation of the NPR recommenda-
tions and found that cross-agency ecosystem planning
and management has been implemented partially
through an interagency task force chaired by the
director of the White House Office on Environmental
Policy (234 DEM A-l, 12/8/94).
The bill has been referred to the Senate Energy and
Natural Resources Committee, which Hatfield chairs.
No hearings on S 93 have been scheduled, a committee
staff member told BNA Jan. 9.G
Hazardous Waste
HARMON ELECTRONICS APPEALS RCR/dECISION
THAT LEVIED HIGHEST PENALTY0Y EPA JUDGE
Harmon Electronics Inc. havappeaied a December
1994 Environmental Protection Agency administra-
tive law judge decision that set a. record-high fine,
arguing that the five-ydar statute of limitations ex-
pired before EPA brought the complaint (In the mat-
ter of Harmon Electronics Inc., EAB, RCRA No.
94-4,1/9/95). y
The agency's Environmental Appeals Board should
review the/Dec. 12, 1994, decision by.ALJF>ank W.
Vanderheyden because of the statute oMunitations
Kit, and also because thevrtcord-setting
$5&C716 civil penalty assessed for alleged hazardous
waste management violations ^inappropriate, the
Grain Vailey, Mo., railroad equipment manufacturer
said in an appeal filed Jan. to
Vanderheyden assessed ,tlCe penalty after EPA's Re-
gion VH headquartered^ Kansas City, Kan., filed a
complaint against Harmon in September 1991 for
several alleged -violations of the Resource Conserva-
tion and Recovery 'Act, including operating a landfill
without a permit, failing to institute a ground water
monitoring pcogram, and not obtaining pnandMl as-
surance foreclosure and past-closure .operations. But
Janxion argued in the appeal that EPA is intruding on
nntinuing negotiations the company is involved in
vith Missouri sute officials tc correct the problems.
The/penalty, the highest ever assessed by an EPA
idministrative law judge; is also inappropriate given
he self-auditing and voluntary actions the company
ook, Harmon argued in the appeal notice.
/ ^
Alligations Stam From Intarnal Audit
According^o the notice of appeal/Harmon Elec-
ronics copducted an internal safetyiudit in 1988 and
iiscover® improper hazardous, waste disposal of
ireon, methylene chloride, toluene, and xylene — sol-
vents used in assembling control and safety equipment
for the railroad indusm^Se company then disclosed
the mismana gemenMK waste solvents to the Missouri
Department of Jfeftiral Resources. According to EPA,
the spent solvents were collected and emptied on the
ground outside the facility every one to three weeks
from 1973 to 1987. .
In 1987, Harmon stopped generating the'nazardou
waste solvents from the processes .at the facility an
switched to water-soluble cleansers for circuit boards.
From June 1988 to the present, Harmon and state
agencies have worked to' investigate and remediate
the activities at the facility. In November 1989, the
sute determined the facility was a hazardous waste
land disposal facility governed by RCRA and the state
hazardous waste management reguiauonar^though
Harmon believed that its investigation^and -remedi-
ation efforts should have been classified under the
sute superfund-like cleanup statute.
Th^ dispute was resolved in February 1991, when
the*ute's final decision classified Harmon as a RCRa
facility. During this time, Harmon was notjpwaipi-
trant, as a government witness alleged- dtfring the
hearing before Vanderheyden. Slmplyf Harmon was
legally challenging its classification as a RCRA land-
fill the appeal notice said.
"Harmon's exercise of its legal rights should not
and cannot be used to increase the penalties assessed
against Harmon," the company said in the notice
apgul. . >' ^—
For the remainder of 1991, Harmon vstS the sttte
worked to establish a closure and post-closure work
plan for a background well Harmon insulled on the
properdin November 1991, Harmon obtained finan-
cial lianmty coverage for the landfill facility, just two
months after the state notified the company it needed
to comply with financial assurance requirements.
A consent decree* between Hanson and the state
was signed in November 1992, and entered into circuit
court in Missouri on March 5,1993.
/
Basis For Appaai
In the meantime, EPA filed^it^complaifit in Sep-
tember 1991, saying that even tbough/ifcrmon dis-
closed the violations and* stopped generating the
hazardous waste solvents, the company still failed to
comply with RCRA^requiremenis' for operating and
closing a landfills'
The filing of' EPA's complaint violates the state
authorization 'provisions ofRCRA and a memorandum
of understanding between the state and EPA esub-
lishingytfte sute RCKA authorizatipB-pcogram, Har-
mon argued in its ajppeaL )
In addition, Um federal Jive-year statute of. limita-
tions (28 USC >2462) amities, barring EPA's 1991 com-
plaint for viola tionrthat occurred in 1980. Harmon
attorneys/Are usfitg the stttute-oMlmitations ruling
from the ttf"decision, which found that the clock
starts rapring for the government to file a complaint
when Be claim first accrues, not when EPA discovers
the violation (Minnesota Mining & Manufacturing
v. EPA. CA DC, No. 92-1126, 3/4/94)/"'
Sue Honegger, an attorney with 'Lathrop & North-
quist in Kansas City, Mo., representing Harmon Elec-
tronics, told BNA Jan. 9,
------- |